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+#### UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff, v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E. STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW.
+
+Defendants, and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+Case Number:
+
+#### VERIFIED STOCKHOLDER DERIVATIVE COMPLAINT
+
+Operating Engineers Construction Industry and Miscellaneous Pension Fund ("Operating Engineers" or "Plaintiff"), for the benefit of nominal defendant JPMorgan Chase & Co. ("JP ME," the "Bank," or the "Company"), brings the following Verified Stockholder Derivative Complaint against Defendants James Dimon, Ashley Bacon, Linda B. Bammann, James A. Bell, John H. Biggs, Crandall C. Bowles, Stephen B. =, Todd A. Combs, David M. Cote, James S. Crown, Mary C. Erdoes, Timothy P. Flynn, Ellen V. Futter, Mellody Hobson, John J. Hogan, Laban P. Jr., John W. Kessler, Robert I. Lipp, Richard A. Manoogian, Michael A. Neal, David C. Novak, Lee R. Raymond, James E. Staley, William C. Weldon, and Barry L. Zubrow. The allegations of this Complaint are based on the knowledge of Plaintiff as to itself and the investigation of counsel, including the review of publicly available information and documents.
+
+### NATURE AND SUMMARY OF THE ACTION
+
+1. Most of the world learned of Jeffrey Epstein's horrific abuses of women and children in 2019, when Epstein was arrested for orchestrating a wide-ranging human trafficking enterprise. Others, however—including those that facilitated Epstein's enterprise—knew of his abusive behavior for more than a decade earlier. JP was one such facilitator. JP served as Epstein's primary bank from at least 1998 to 2013, during which time he operated as many as 55 accounts: some in his own name, some in the name of shell companies and sham nonprofits, and some in the names of his victims, associates, and recruiters.
+
+2. For nearly fifteen years, Epstein relied on these accounts to abuse women and children. Epstein used his JP accounts to transfer money to recruiters that trafficked new victims and to withdraw vast amounts of cash to pay off his victims. During certain periods, Epstein reportedly withdrew up to \$80,000 in cash multiple times a month; he once withdrew more than \$750,000 in cash in a single year. Epstein is now infamous for using cash to pay his victims, and his extraordinary cash withdrawals were obviously suspicious even without knowledge of his abusive conduct.
+
+3. But JP knew of Epstein's abusive conduct many years before his arrest, and internally held deep concerns about precisely why Epstein was withdrawing vast amounts of cash and transferring hundreds of thousands of dollars to "modeling" agencies. As early as 2006, when Epstein was arrested for solicitation of a minor, JP knew not only that Epstein was abusing young women and children, but that he paid his victims in cash—something that one of JP top executives has admitted. In 2008, in 2010, and multiple times in 2011, JP employees internally shared reports about Epstein's abuses and expressed concern about the Bank's ongoing relationship with him. In 2011, JP employees explicitly questioned whether a previous payment to a "model management" agency was "payment for services as a procurer."
+
+4. Knowledge of Epstein's abusive conduct extended to the very top of the Company's C-suite. Most notoriously, Jes Staley (who, until 2013, served as the chief executive officer ("CEO") of JP Investment Bank) shared a deep personal friendship with Epstein. Although JP is now attempting to lay all blame for its institutional failures on Staley alone in an attempt to escape legal and reputational harm, it is clear that Staley could not have sustained and concealed a 15+ year banking relationship involving tens of millions of dollars without the knowledge and assistance of others within JP . Mary Erdoes (who has served as CEO of JP Asset & Wealth Management division) paid numerous visits to Epstein's home and has admitted that she and JP knew of Epstein's abuses by 2006. Erdoes is known as a top lieutenant to the Bank's longtime CEO, Jamie Dimon. And Dimon himself appears to have been personally involved in sanctioning the Bank's relationship with Epstein: one August 2008 document references Epstein's \$120 million with JP being in question "pending Dimon review."
+
+5. Despite this top-to-bottom knowledge, JP Board did nothing. JP knew that Epstein was a serial abuser that relied heavily on cash payments, and that Epstein regularly withdrew vast sums of cash from his JP accounts. But upon information and belief, JP consistently failed to file suspicious activity reports ("SARs") that it was required to file when it suspected potential criminal activity—as it clearly did. This failure persisted through Epstein's entire 15+ year history with the Bank, and persisted for years even after JP terminated Epstein's accounts in 2013. This failure persisted, in fact, through the time of Epstein's final arrest in 2019, until which time Epstein continued to commit his prolific abuses.
+
+6. This failure to file SARs and otherwise comply with similar anti-money laundering ("AML") and know-your-customer ("KYC") regulations is nothing new for JP Rather, it is a symptom of a broader, years-long failure of governance and oversight by JP board of directors—a failure for which JP was previously cited and penalized by regulators, in 2013 and 2014. In 2013, both the OCC and the Federal Reserve accused JP of failing to comply with federal AML laws and regulations, including because the Bank failed to file timely SARs. JM was hit with a \$350 million sanction in 2014 due to its continuing AML compliance failures. Not only did the Company face civil penalties, it was faced criminal liability as well: the Bank pleaded guilty in 2014 to two felony counts relating to failures to comply with AML rules, including the failure to file SARs.
+
+7. Now, JP is exposed to substantial legal risk due its role in helping conceal Epstein's crimes. One of Epstein's victims, identified only as "Jane Doe 1", has brought several claims (on behalf of herself and other victims) against the Bank for its role in Epstein's abuse of her. The government of the U.S. Virgin Islands has also initiated litigation against the Bank for similar masons, and is seeking significant monetary damages, including punitive and treble damages.
+
+8. All told, JP has suffered and will continue to suffer substantial monetary and reputational harm for its longstanding role in assisting the most egregious sex trafficker in
+
+modem history. Had JP Board and senior officers taken their oversight responsibilities seriously, JP would have consistently reported Epstein's suspicious practices and would have terminated its relationship with him much sooner than it actually did. Plaintiff brings this action on behalf of JP to hold these directors and officers to account for their longstanding governance failures.
+
+#### Till. P 11Z I I E\$
+
+9. Plaintiff is a stockholder ofJP and has held JP since 2010.
+
+10. Nominal Defendant JPMorgan Chase & Co. is a Delaware corporation with its principal place of business in New York City, New York. JP principal bank subsidiary is JPMorgan Chase Bank, National Association.
+
+11. Defendant James Dimon ("Dimon") has been a director of JP since 2004. Dimon has been JP CEO since 2005 and Chairman of the Board since 2006. Dimon is an individual and is believed to be a resident of New York, New York.
+
+12. Defendant Ashley Bacon ("Bacon") has been JP Chief Risk Officer since 2013. Bacon is an individual and is believed to be a resident of Greenwich, Connecticut.
+
+13. Defendant Linda B. Bammann ("Bammann") has been a director of JP since 2013. Bammann has been Chair of the Risk Committee since 2017, and a member of the Risk Committee from 2014-2017. Bammann is an individual and is believed to be a resident of Ocala, Florida.
+
+14. Defendant James A. Bell ("Bell") was a JP director from 2011-2020. During that time, Bell was a member of the Audit Committee from 2012-2016, and Chair of the Audit Committee from 2017-2020. Bell is an individual and is believed to be a resident of Beverly Hills, California.
+
+15. Defendant John H. Biggs ("Biggs") was a director of JP from 2003-2008. During that time, Biggs was a member of the Audit Committee from at least 2006-2008. Biggs is an individual and is believed to be a resident of St. Louis, Missouri.
+
+16. Defendant Crandall C. Bowles ("Bowles") was a JP director from 2006- 2018. Bowles was a member of the Audit Committee from 2007-2018. Bowles is an individual and is believed to be a resident of Fort Mill. South Carolina.
+
+2004. 17. Defendant Stephen B. (la has been a director of JP is an individual and is believed to be a resident of Dillon, Montana. since
+
+18. Defendant Todd A. Combs ("Combs") has been a director of JP since 2016. Combs was a member of the Risk Policy Committee from 2017-2019. Combs is an individual and is believed to be a resident of Omaha, Nebraska.
+
+19. Defendant David M. Cote ("Cote") was a director of JP from 2007-2013. During that time, Cote was a member of the Risk Policy Committee from 2008-2013. Cote is an individual and is believed to be a resident of Pine Plains, New York.
+
+20. Defendant James S. Crown ("Crown") has been as a director of JP since 2004. Crown was a member of the Risk Committee from at least 2006-2007 and since 2017, and Chair of the Risk Committee from 2007-2017. Crown is an individual and is believed to be a resident of Chicago, Illinois
+
+21. Defendant Mary Callahan Erdoes ("Erdoes") joined JP in 1996 as head of fixed income for high-net-worth accounts. She became CEO of JP Private Bank in 2005. In September 2009, Erodes obtained her current role as CEO of JP Asset & Wealth Management division. Erodes is an individual and is believed to be a resident of Miami, Florida.
+
+22. Defendant Timothy P. Flynn ("Flynn") has been a director of JP since 2012. Flynn has been Chair of the Audit Committee since 2021, was a member of the Audit Committee from 2017-2021, and was a member of the Risk Policy Committee from 2013-2017. Flynn is an individual and is believed to be a resident of Marana, Arizona.
+
+23. Defendant Ellen V. Futter ("Futter") was a director of JP from 2001-2013. Futter was a member of the Risk Policy Committee from at least 2006-2013. Futter is an individual and is believed to be a resident of New York, New York.
+
+24. Defendant Mellody Hobson ("Hobson") has been a director of JP since 2018. Hobson was a member of the Audit Committee in 2019, and has been a member of the Risk Committee since 2020. Hobson is an individual and is believed to be a resident of Chicago, Illinois.
+
+25. Defendant John J. Hogan ("Hogan") was JP Chief Risk Officer from 2012-2013. Hogan is an individual and is believed to be a resident of Naples, Florida.
+
+26. Defendant Laban P. M, Jr. a") was a director of JP from 2004-2020. During that time, was Chair of the Audit Committee from at least 2006-2016, and a member of the Audit Committee from 2017-2020. is an individual and is believed to be a resident of Harbor Springs, Missouri.
+
+27. Defendant John W. Kessler ("Kessler") was a director of JP from 1995- 2007. Kessler is an individual and is believed to be a resident of New Albany. Ohio.
+
+28. Defendant Robert I. Lipp ("Lipp") was a director of JP from 2003-2009. During that time, Lipp was a member of the Risk Committee from at least 2006-2009. Lipp is an individual and is believed to be a resident of New York, New York.
+
+29. Defendant Richard A. Manoogian ("Manoogian") was a director of JP from 1978-2007. During that time, Manoogian was a member of the Audit Committee from at least 2006-2007. Manoogian is an individual and is believed to be a resident of Grosse Pointe Park, Michigan.
+
+30. Defendant Michael A. Neal ("Neal") has been a director of JP since 2014. Neal has been a member of the Audit Committee since 2021, and was a member of the Risk Policy Committee from 2014-2020. Neal is an individual and is believed to be a resident of Naples, Florida.
+
+31. Defendant David C. Novak ("Novak") was a JP director from 2004-2012. During that time, Novak was a member of the Compensation and Management Development Committee from 2006-2012, and was Chair of the Corporate Governance and Nominating Committee from 2006-2012. Novak is an individual and is believed to be a resident of Southampton, New York.
+
+32. Defendant Lee R. Raymond ("Raymond") was a director of JP from 2001- 2020. Raymond is an individual and is believed to be a resident of Westlake, Texas.
+
+33. Defendant James E. Staley ("Staley") was the CEO of JP Investment Bank from September 2009 through January 2013. Previously, Staley was the CEO of JP Asset Management division from 2001-2009, and was the head of JP Private Banking division from 1999-2001. Staley is an individual and is believed to be a resident of Manhattan, New York.
+
+34. Defendant William C. Weldon ("Weldon") was a director of JP from 2005- 2019. Weldon is an individual and is believed to be a resident of North Palm Beach, Florida.
+
+35. Defendant Barry L. Zubrow ("Zubrow") was JP Chief Risk Officer from 2007-2012. Zubrow is an individual and is believed to be a resident of West Palm Beach, Florida.
+
+36. Defendants Bammann, Bell, Biggs, Bowles, =, Combs, Cote, Crown, Dimon, Flynn, Futter, Hobson, Kessler, Lipp, Neal, Novak, Manoogian, Raymond, and Weldon are referred to collectively herein as the "Director Defendants."
+
+37. Defendants Bacon, Dimon, Erdoes, Hogan, Staley, and Zubrow are referred to collectively herein as the "Officer Defendants."
+
+38. The Director Defendants and Officer Defendants are collectively referred to herein as "Defendants."
+
+## RELEVANT NON-PARTIES
+
+39. Alicia Boler (a) has been a director of JP since March 2023.
+
+40. Alex Gorsky ("Gorsky") has been a director of JP since July 2022.
+
+41. Phebe N. Novakovic ("Novakovic") has been a director of JP since 2020.
+
+42. Virginia M. Rometty ("Rometty") has been a director of JP since 2020.
+
+## JURISDICTION AND VENUE
+
+43. The Court has jurisdiction over this action pursuant to 28 U.S.C. § 1332. The Court has supplemental jurisdiction over the state law claims asserted herein pursuant 28 U.S.C. § 1367(a). This action is not a collusive one to confer jurisdiction on a court of the United States which it would not otherwise have.
+
+44. Venue is proper in this Court because JP has its principal place of business in this district, Plaintiff's claims arose in this district, and JP has suffered and will continue to suffer harm in this district. Venue is further proper in this Court because various actions related to the allegations asserted herein, including Doe v. JP below), are currently pending before this Court. and USV/ v. JP (defined
+
+#### PROCEDURAL BACKGROUND
+
+45. JP is currently defending allegations from two distinct lawsuits stemming from its facilitation and concealment of Epstein's abuse. First, a plaintiff identified as "Jane Doe 1", on behalf of herself and other victims of Epstein's abuse, asserted several claims against the Company's primary banking subsidiary, JP Chase Bank, N.A., in the litigation styled Jane Doe I v. JP Chase Bank, N.A., 22-cv-10019 (JSR) ("Doe v. JP la"). Second, the government of the U.S. Virgin Islands also asserted several claims against JP Chase Bank, N.A. in the litigation styled Government of the United States Virgin Islands v. JP Chase Bank, N.A., 22-cv- 10904 (CSR) ("USV/ v. JP M").
+
+46. In both actions, the plaintiffs broadly allege that for several years, JP knew about Epstein's abusive conduct and knew about Epstein's suspicious use of his many accounts at the Bank, yet failed to comply with federal regulations to report his suspicious activity. This failure and concealment, in turn, helped Epstein's systematic abuse to continue unchecked. Plaintiffs in both actions seek monetary damages, including punitive and treble damages in the USV/ v. JP action. JP therefore faces a material risk of substantial monetary liability, above and beyond the significant reputational harm that JP has already suffered and will continue to suffer as a result of its longstanding facilitation and concealment of Epstein's crimes. JP also faces the risk of fines or monetary damages as the result of potential governmental investigations into its conduct.
+
+# SUBSTANTIVE ALLEGATIONS
+
+# I. EPSTEIN'S DECADES OF ABUSIVE CONDUCT
+
+47. The shocking extent and gravity of Epstein's abuses are now well known. For more than two decades, Epstein operated a vast network of shell companies, intermediaries, and enablers for the sole purpose of trafficking and abusing young women at his properties, including in the U.S. Virgin Islands.
+
+48. Epstein is reported to have begun his systematic exploitation of young women as early as the 1990s. But since at least 2001, Epstein trafficked young girls and women to the U.S. Virgin Islands, where he then had them transported to his private island, Little St. James.' He also trafficked women to New York and to other properties he owned. Epstein and his associates often deceived these girls and young women into traveling with promises of modeling contracts, employment, or educational opportunities. Other times, Epstein's abuse began as a demand for a massage, which rapidly evolved into abuse. Once trafficked to the U.S. Virgin Islands, Epstein and others in his network exploited and abused these women, and then ensured their silence with both threats and payoffs. Epstein was infamous for paying his victims in cash, although he on occasion also wired money directly to both victims and allies.'
+
+49. The full scale of Epstein's abuses is hard to comprehend. Epstein is accused of trafficking and abusing girls as young as I I years old, reflecting his repulsive preference of the "younger the better."3 Air traffic controllers and other airport personnel in the U.S. Virgin Islands reported seeing Epstein disembark from his plane with girls that appeared to be between 11 and 18 years old. In one harrowing instance, a 15 year old victim that Epstein abused on Little St.
+
+Government of the United States Virgin Islands v. Indyke, et al. ST-20-CV-14, Second Am. Compl. (Nov. 30, 2022) at 149 (hereinafter "USVI State Complaint").
+
+<sup>2</sup> Government of the United States Virgin Islands v. JP Chase Bank, N.A., 22-cv-10904 (CSR), Second Am. Compl. (Apr. 12, 2023) at 142 (hereinafter "USVI Complaint").
+
+<sup>3</sup> Jane Doe 1 v. JP Chase Bank, NA., 22-cv-10019 (JSR), First Am. Compl. (Jan. 13, 2023) at 1126 (hereinafter "Doe Complaint").
+
+James attempted to escape by swimming off the island. Epstein organized a search party, found the victim, confiscated her passport, and threatened her with physical harm if she did not submit°
+
+50. Epstein trafficked many of his victims from Eastern Europe and sometimes kept the same girls and women in servitude for several years. For example, Epstein is accused of having flown one victim to his island dozens of times between 2004 and 2017; and another more than 50 times between 2000 and 2002. This meant that Epstein eventually had to grapple with immigration concerns. To address this problem, Epstein forced some of his victims to marry his American citizen associates (or even other victims), and then helped finalize arrangements with immigration authorities.5 Epstein is accused of having forced at least three victims into marriages, and then threatening them with harm if they attempted to leave.
+
+51. Epstein's appetite for abuse was seemingly insatiable. Epstein is reported to have regularly abused up to 3-4 victims each day—a demand that even Epstein's extensive network struggled to supply. Epstein therefore demanded that his victims themselves help deceive and recruit other victims. To this end, Epstein often instructed his victims to go to night clubs or on shopping trips to help identify other unsuspecting women and girls that they might be able to entrap. Epstein paid an additional fee for each new victim that an existing victim lured in.
+
+52. The frequency and duration of his crimes make clear that Epstein could not have orchestrated his abuse without both an extensive network of allies and enablers, and steady, unquestioned access to large amounts of cash. In JP M, Epstein had both.
+
+<sup>4</sup> USVI State Complaint, ¶60.
+
+<sup>5</sup> USVI State Complaint. 163.
+
+## II. JP ENABLED EPSTEIN'S CRIMES FOR YEARS
+
+53. Epstein was a JP client from at least 1998 through 2013. Over this time, JP serviced roughly 55 accounts that belonged or were related to Epstein, collectively worth hundreds of millions of dollars. In addition to accounts in his own name, Epstein also operated many JP accounts in the names of other companies and non-profit entities that often had no legitimate business purpose. These entities included 2013 Butterfly Trust, Coatue Enterprises, LW, C.O.U.Q. Foundation, Enhanced Education, Financial Trust Company, Inc., HBRK Associates, Inc., Hyperion Air, Inc, JEGE, Inc., JEGE, LLC, NES, LLC, Plan D, LLC, Southern Financial, LW, and Southern Trust Company, each of which had accounts with JP . Epstein used many of these entities to make and conceal payments to his victims and his associates or, as the U.S. Virgin Islands alleges, to help shield his assets from judgment.
+
+54. Over the many years that Epstein served as a star JP client, he used his 55+ accounts with the Bank extensively to facilitate his abuse. According to the U.S. Virgin Islands government, Epstein paid at least 20 of his victims through JP accounts, and these victims collectively received in excess of \$1 million. Epstein also used his JP accounts to pay his associates and enablers: the U.S. Virgin Islands government alleges that Epstein paid nearly \$1.5 million to known recruiters.
+
+55. The details of these enormous payments are deeply troubling. Epstein paid the plaintiff identified as Jane Doe 1, for example, more than \$600,000 through his JP accounts between 2003 and 2013. Epstein's abuse of Doe 1 began when she was only 14 years old.6 In an obvious sign that something was amiss, Doe 1 listed Epstein's New York City townhouse as her address for purposes of the many payments she received from Epstein.
+
+<sup>6</sup> USVI Complaint, 166.
+
+56. More troublingly, Epstein also regularly withdrew millions of dollars from his JP accounts—in cash. As early as 2006, a JP Rapid Response Team noted that Epstein routinely withdrew \$40,000 to \$80,000 in cash from his accounts several times each month, and more than \$750,000 per year. In each of 2004 and 2005, Epstein withdrew more than \$800,000 in cash. Epstein also used his JP accounts to make at least 95 foreign remittances to unknown payees—another blatantly suspicious pattern of conduct.
+
+57. Some of Epstein's use of cash is so obviously illegitimate that it almost defies belief. For example, the company that owned and operated Epstein's private plane (Hyperion Air, Inc.) issued more than \$547,000 in checks—payable to cash—for "fuel expenses when traveling to foreign countries."7 Apart from the absurdity of paying for hundreds of thousands of dollars' worth of jet fuel in cash, some of these checks were issued when Epstein was under house arrest,' and plainly unable to travel anywhere.
+
+58. Similarly, between January 2012 and June 2013, Hyperion converted more than \$120,000 into foreign currency, with the constituent cash withdrawals either exceeding the typical \$10,000 reporting threshold, or being structured in a way to avoid meeting this threshold. Epstein also used other entities under his control to funnel payments to his victims and associates. For example, Epstein used a charitable organization he controlled (and which had an account with JP M) to pay \$29,464 to three young women, and used another organization to pay \$124,232 to Leslie Wexner, who is now known to have been a vital part of Epstein's network.
+
+<sup>7</sup> USVI Complaint, ¶67.
+
+<sup>8</sup> As discussed further below, Epstein was arrested in Florida in 2006 on charges of soliciting a minor for prostitution, and entered into a plea agreement in 2008.
+
+### III. JP WILLFULLY IGNORED AND FAILED TO REPORT EPSTEIN'S HIGHLY SUSPICIOUS PRACTICES
+
+59. JP knew of Epstein's true nature at least as early as 2006. The previous year, press reports emerged that claimed that Epstein paid a I4-year old girl in Palm Beach, Florida for a massage and then proceeded to abuse her. These press reports prompted other Epstein victims to come forward with similar allegations. In 2006, Epstein was arrested and indicted in Florida for solicitation of a minor, amidst additional extensive press reports about his crimes.
+
+60. JP was immediately aware of Epstein's arrest. In 2006, the same year Epstein was arrested, JP Global Corporate Security Division found "[s]everal newspaper articles ... that detail the indictment of Jeffrey Epstein in Florida on felony charges of soliciting underage prostitutes"9 (i.e. raping children). Despite these reports and Epstein's indictment, JP decided to retain Epstein as a client—while concluding that his account "should be classified as high risk" and require special approval.10
+
+61. JP knowledge of Epstein's crimes at this time was not limited to lowerlevel employees, but extended all the way to the top. At her deposition in the USV/ v. JP action, Mary Erdoes (who was CEO of JP Private Bank from 2005 until she became CEO of the Asset & Wealth Management Division in 2009) admitted that JP was aware in 2006 not only that Epstein was abusing women and underage girls, but that Epstein paid these victims in cash. Crucially, this was the same year that a team at JP made an internal report that Epstein was withdrawing up to \$80,000 in cash at a time, multiple times a month.
+
+<sup>9</sup> USVI Complaint, 144.
+
+<sup>1°</sup> USVI Complaint,144.
+
+62. In 2008, Epstein pled guilty to several of the charges that he faced in Florida, including solicitation of a minor for prostitution. As part of his plea arrangement, Epstein was sentenced to serve 18 months in jail and was required to register as a sex offender." To the extent JP had any doubts about the allegations against Epstein in 2006, Epstein's guilty plea in 2008 erased them.
+
+63. Internally, Epstein's guilty plea led some of JP employees to assume that the Bank would immediately terminate its sprawling relationship with the now-convicted sex trafficker. But they would be mistaken, as JP senior-most executives decided to maintain this lucrative, if problematic, relationship. In August 2008, a JP employee wrote that she "would count Epstein's assets as a probable outflow for '08 (\$120mm or so?) as I can't imagine it will stay (pending [Jamie] Dimon review)."I2
+
+64. Given that JP continued to service Epstein's accounts for at least five more years, the "Dimon review" evidently resulted in a decision not to take any action against Epstein following his guilty plea but, rather, to retain the lucrative relationship. The same year, in a reflection of JP decision to brush off Epstein's known crimes, Erdoes received an email asking her whether Epstein was at an event "with miley cyrus"—who was only 16 years old at the time.13
+
+65. Press reports about Epstein's abusive conduct continued to emerge in subsequent years, and JP compliance employees continued to express concerns about the Bank's
+
+I Epstein's full non-prosecution agreement with Florida became public in 2009. This agreement alleged that Epstein trafficked and engaged in illicit sexual conduct with minors, including across state lines.
+
+<sup>12</sup> USVI Complaint, y151.
+
+<sup>13</sup> USVI Complaint.¶95.
+
+continued patronage of someone with Epstein's history. In 2010, JP learned of even more allegations in the press against Epstein, detailing his trafficking of women and minors for abuse. In an internal email, an employee in JP risk management division referred to "new allegations of an investigation related to child trafficking," and asked whether the Bank was "still comfortable with this client who is now a registered sex offender."14 Other JP compliance employees decided that Epstein "should go."15 But reflecting the Bank's fundamental attitude to Epstein's crimes, a different JP risk management employee dismissed these disturbing reports as routine: "In my short tenure working on the account these stories pop up including these from the summer."16
+
+66. The next year, in January 2011, JP once again was made keenly aware of yet more allegations of human trafficking against Epstein. And yet again, JP brushed off the allegations. That month, JP conducted a review of Epstein's accounts because a "few news stories during 2010 connect[ed] Jeffrey Epstein to human trafficking."17 The U.S. Virgin Islands alleges that JP coverage team "met to discuss the situation and agreed to enhance monitoring and document a discussion with the client."'s Unsurprisingly, Defendant Jes Staley the CEO of JP Investment Bank who seemingly participated in Epstein's crimes, as discussed in Section IV below—was the JP executive that the Bank entrusted to hold this "discussion" with Epstein. Also unsurprisingly, Epstein claimed "there was no truth to the
+
+USVI Complaint,145.
+
+<sup>15</sup> USVI Complaint198.
+
+<sup>16</sup> USVI Complaint, 145.
+
+<sup>17</sup> USVI Complaint, 146.
+
+la USVI Complaint, ¶47.
+
+allegations" against him and "no evidence."19 JP internally concluded that it would "continue to monitor the accounts and cash usage closely going forward."20
+
+67. In other words, JP knew that Epstein was a convicted sexual offender who heavily relied on his cash to pay his victims and his associates. JP also knew that Epstein regularly withdrew huge amounts of cash from his many accounts with the Bank. Yet JP response was to simply "monitor" Epstein's already-extraordinary "cash usage," rather than take any measures to report his blatantly suspicious transactions to the authorities. In a hint that Epstein was too large of a client for JP to take action against, the Bank had granted Epstein a new \$50 million line of credit only weeks earlier, in December 2010.
+
+68. Only two months later, JP Global Corporate Security Division internally circulated even more devastating reports about Epstein's abuses. In March 2011, this division reported that "[n]umerous articles detail various law enforcement agencies investigating Jeffrey Epstein for allegedly participating, directly or indirectly, in child trafficking and molesting underage girls."2I Even more damningly, this report also noted that Epstein had "settled a dozen civil lawsuits out of court from his victims regarding solicitation."22 This made it abundantly clear to JP that Epstein was not a one-off offender—he was a prolific, serial abuser of women and girls that he paid through his many JP bank accounts.
+
+69. This same March 2011 report also noted that a company named "MC2 Model Management and Jeffrey Epstein engaged in racketeering that involved luring in minor children
+
+<sup>19</sup> USVI Complaint, 147.
+
+<sup>20</sup> USVI Complaint.¶47
+
+<sup>21</sup> USVI Complaint,148.
+
+<sup>22</sup> USVI Complaint, ¶48.
+
+for sexual play for money," and that MC2's owner was a "frequent passenger on Epstein's private jet and often visited Epstein in jail." Worse, the report noted that Epstein paid MC2 \$1 million in 2005, and that it was "unknown if the money was given as a secret investment or payment for services as a procurer."24
+
+70. JP was plainly concerned that Epstein was using his accounts with the Bank to "procure" ever more victims. This concern within the Bank soon also spread to others within Epstein's orbit. Although most of the public learned of Ghislaine Maxwell's key role in Epstein's abuses only after her arrest in 2019, JP suspected her involvement years earlier. In August 2011, Maxwell applied to open a new account with JP for a "personal recruitment consulting business."25 Internally, JP AML director asked: "What does she mean by personal recruitment?? Are you sure this will have nothing to do with Jeffrey? If you want to proceed, I suggest that we flag this as a High Risk Client."26 While it is unclear how JP may have treated Maxwell internally, the Bank plainly did not ever report Maxwell's suspicious "recruitment" activities to regulators.
+
+71. Also in 2011, a senior JP compliance official who reviewed the Bank's relationship with Epstein warned that there was "[Ijots of smoke" and "Mots of questions" surrounding Epstein's criminal behavior.27 According to the U.S. Virgin Islands' complaint against JP , these included that:
+
+<sup>23</sup> USVI Complaint, 148.
+
+<sup>24</sup> USVI Complaint,148.
+
+<sup>23</sup> USVI Complaint,149.
+
+<sup>26</sup> USVI Complaint,149.
+
+<sup>27</sup> USVI Complaint, 198.
+
+- Epstein "is alleged to be involved in the human trafficking of young girls and law enforcement is also allegedly investigating his involvement in this activity."
+- "He is also an alleged personal associate of the CEO of the Investment Bank (Jes Staley)."
+- "AML Operations went to a [Private Bank] risk meeting late last week requesting that we exit this relationship."
+- "[W]hether Epstein if further exposed could have a potential serious impact."
+- "The one new concerning thing is the one article about the DOJ investigation is saying they brought under age girls to the US via a modeling agency M2 that is owned by a guy named Brunel. Turns out the banker said today we extended Epstein a loan in relation to this modeling agency." The writer claims that the agency is "legit" and that "it would be hard for us to tell" if "girls were exploited via their contract or arran ement." The loan was a letter of credit provided by JP to MC2 Model Management.
+- In 2004, Epstein sponsored private bank accounts and credit cards for two 18 year olds "that appear to be part of his inner entourage. One is mentioned in many of the recaps of the escapades as a willing participant and assistant when hosting visitors. She has received about 450,000 since opening from Epstein . . Both can be put in Palm Beach during 2004, by way of debit charges, which was when most allegations were from .... He did pay other girls, many models no huge amounts. Sugar Daddy!"
+- "His foundation account did pay donations to the Palm Beach Police Dept as reported just before the case started. The same foundation account did pay monies direct to models and payments direct to specialty schools (massage, culinary) and university's on behalf of models/aspiring actresses. Nothing was astronomical."
+- "His business accounts Fiduciary we saw no client activity. I know his biggest client, Wexner parted ways when he was convicted. His [Due Diligence Reports] say he manages a few private clients money but never says who. I would like to know if in fact he is managing anyone's money at this point or is it all his money. We saw no evidence of disbursements even in the rocky years 08-09. When the well to do were running to their mattresses, he did not have any distributions from his accounts at Bear or JP. He does have money at other institutions so maybe it happened there."
+
+USVJ v. JP Complaint,198.
+
+72. Despite unequivocally knowing that Epstein was a serial sex offender, and despite the obviously suspicious nature of Epstein's activity with the Bank, JP took no corrective action against Epstein for years. Finally, in 2013, JP terminated its relationship with Epstein; it continued to do business with him for several years afterward (as detailed below). The year that JP terminated Epstein's accounts, the Bank noted that "[pier bank policy, felons are considered high risk and require additional approval."28 Epstein had been a convicted felon for almost a decade before his banking accounts were terminated. That the Company left the accounts in place for so long, despite such deeply troubling, public accounts of his crimes, suggests either that the Bank's senior-most executives reviewed and approved Epstein's ongoing relationship with the Bank despite knowing about his crimes; or the Bank's oversight system failed, allowing Epstein's abusive conduct to continue unchecked.
+
+## IV. .JP SENIOR-MOST EXECUTIVES SUPERVISED THE BANK'S RELATIONSHIP WITH EPSTEIN, EVEN YEARS AFTER JP TERMINATED EPSTEIN'S ACCOUNTS
+
+73. JP was clearly fully aware of Epstein's abusive conduct, and its lower-level employees held deep concerns about the Bank's ever-deeper relationship with Epstein. But JP senior-most executives did not share this concern—and this extends far beyond just Defendant Staley, Epstein's close friend and apparent fellow abuser (as discussed infra), whom JP is now attempting to hold solely responsible for its longstanding failures. Mary Erdoes who currently serves as the CEO of JP Asset and Wealth Management division—visited Epstein at his New York home in both 2011 and 2013. Erdoes is also reported to have exchanged
+
+<sup>28</sup> USVI Complaint, ¶50.
+
+"dozens of emails" with Epstein, including with regard to a charitable fund that JP considered launching together with Epstein.29 Similarly, John Duffy—who served as Vice Chairman of JP and as the CEO of JP private bank for ultrawealthy clients also visited Epstein at his New York home in April 2013. Just one month later, the private bank that Duffy ran re-authorized Epstein to borrow money against his accounts, despite JP compliance officials' repeated warnings about Epstein's suspicious practices and criminal behavior. Another senior JP executive who worked at the private bank, Justin Nelson, visited Epstein's New York home around six times between 2014-2017—after the bank supposedly terminated Epstein's accounts. Nelson also visited Epstein at his ranch in New Mexico in 2016. Defendant Kessler—who was a member of the Board from 1995 to 2007—was former college classmates, close friends and business partners with Epstein's main benefactor, Leslie Wexner ("Wexner"), with whom Kessler co-founded a real estate development business. Wexner, a multibillionaire, has been called Epstein's "biggest client" and likely helped provide Epstein with a substantial part of the wealth that enabled his scheme of sexual abuse and predation.
+
+74. These ties pale in comparison, however, to Defendant Staley's intimate—and potentially criminal—relationship with Epstein. Staley led JP Private Banking division (which was later run by Duffy) from 1999-2001, during which time he formed a close relationship with Epstein. Staley later served as the CEO of JP Asset Management division from 2001 until 2009, and was then promoted in 2009 to serve as the CEO of JP Investment Bank. Staley left JP in 2013: the same year that the bank terminated Epstein's accounts.
+
+75. Between 2008 and 2013, Staley used his JP email account to exchange some 1,200 emails with Epstein, reflecting the deep bond the two men shared. Some of these
+
+<sup>&</sup>quot; WSJ Article.
+
+emails suggest that Staley may have participated in or taken advantage of Epstein's criminal trafficking operation. In December 2008, for example, Epstein and Staley discussed Staley visiting Epstein at his residence in Palm Beach. Although Epstein was not going to be in Palm Beach at the time, Epstein invited Staley to use his house. In early January 2009, around the time that Staley was staying at Epstein's house in Palm Beach, Epstein wired \$2,000 from his JP account to a woman with an Eastern European surname. (Many of the women that Epstein trafficked were from Eastern Europe).
+
+76. Later that same year, Epstein and Staley again discussed getting together, this time in London.3° In late August 2009, Epstein asked Staley whether he would need anything while he was in London; Staley said yes. Just two days later, Epstein again used his JP account to wire \$3,000 to the same woman he had paid while Staley was in Palm Beach. This, of course, was after Epstein's 2008 plea agreement related to his charges for solicitation of a minor in Florida.
+
+77. Just months later, in November 2009, while Epstein was in jail, Staley again took advantage of Epstein's hospitality—but this time at Epstein's now-infamous private island, Little St. James. While there, Staley wrote Epstein via email: "So when all hell breaks lo[o]se, and the world is crumbling, I will come here, and be at peace. Presently, I'm in the hot tub with a of wine. This is an amazing place. Truly amazing. Next time, we're here together. I owe you much. And I deeply appreciate our friendship. I have few so profound."3'
+
+78. The following month, Staley made clear that he was fully aware of Epstein's crimes and the risk that his ongoing relationship with Epstein posed to him. On December 4, 2009, Staley seemingly met with Epstein in New York, and then wrote to him via email: "I realize the danger
+
+<sup>3°</sup> USVI Complaint, 155.
+
+<sup>11</sup> USVI Complaint, ¶56.
+
+in sending this email. But it was great to be able, today, to give you, in New York City, a long heartfelt, hug."32
+
+79. The next day and later that same month, Epstein sent pictures of young women to Staley, to which Staley responded with cryptic commentary. Staley again visited Little St. James the following month, in January 2010. Later that year, in July, Staley had the following exchange with Epstein via email, strongly suggesting that Epstein was procuring victims for Staley:
+
+Staley: "Maybe they're tracking u? That was fun. Say hi to Snow
+
+Epstein: "[w]hat character would you like next?"
+
+Staley: "Beauty and the Beast"
+
+Epstein: "[W]ell one side is available."33
+
+80. After the government of the U.S. Virgin Islands sued JP in this Court, JP filed its own complaint against Staley, effectively alleging that Staley was solely responsible for the Bank's longstanding relationship with Epstein, and that Staley concealed Epstein's criminal activity from JP But the allegations detailed above, and those brought by Doe 1 and the U.S. Virgin Islands government, make clear that employees and senior executive officers across JP were fully aware of Epstein's abusive conduct, and fully aware that Epstein was using his many JP accounts in a manner that was highly suspicious, if not obviously illegitimate. JP effort to paint Staley as the sole wrongdoer is little more than an attempt to evade legal and reputational responsibility for knowingly failingly to report—and thereby enabling—Epstein's criminal conduct for more than a decade.
+
+<sup>32</sup> USVI Complaint,¶57.
+
+<sup>33</sup> USVI Complaint, 161.
+
+#### V. BY FAILING TO TAKE ACTION IN RESPONSE TO NUMEROUS RED FLAGS CONCERNING EPSTEIN'S CONDUCT, THE DIRECTOR DEFENDANTS BREACHED THEIR FIDUCIARY DUTIES
+
+81. The Board's most fundamental responsibility is to ensure that the Company is operating within the law. JP M, which operates a national bank, is subject to stringent requirements with respect to detecting and reporting potentially criminal activity. But instead of conducting effective oversight of JP operations, the Board sat idly by while the Company was used to facilitate a massive sex trafficking enterprise. Instead of ensuring that the appropriate reports of suspicious activity were filed with federal authorities, for years the Board allowed the Bank to continue to rake in fees from Epstein's dozens of accounts. Even after the Company closed Epstein's accounts, the Board continued to abdicate its responsibility to file SARs. Finally, the Board failed to act with respect to its own executive, Staley, who knew about and participated in Epstein's pernicious sex-trafficking ring.
+
+## A. COMPLYING WITH FEDERAL BANKING LAWS AND REGULATIONS IS MISSION CRITICAL FOR JP
+
+82. JP and its commercial bank subsidiaries are regulated and supervised by numerous regulatory agencies, both domestically and internationally, including the U.S. Federal Reserve Board and the Office of the Comptroller of the Currency ("OCC"), as well as other federal agencies, state banking and insurance departments, and international financial services authorities.
+
+83. JP acknowledges that the Company is "highly regulated" and represents in its Code of Conduct that legal compliance with those laws and regulations "is not just a critical part of our business, but fundamental to who we are." It advises its employees and directors that they must "comply with the later, spirit, and intent of laws, regulations and Firm policies," and that any violations "may weaken customer confidence, put our reputation at risk, impact market integrity, or result in regulator criticism, legal actions, fines or penalties, or other negative
+
+repercussions." JP employees and directors are prohibited from engaging in outside activities that "reflect adversely on JP or give rise to a real or apparent conflict of interest with [their] duties to the firm." Dimon himself has asserted that the Company has "zero tolerance" for improper behavior and that the bank complies with "the letter and spirit of the laws and regulations everywhere we do business."34
+
+84. Financial institutions, like JP M, are susceptible to serving as conduits for significant financial crimes, including money laundering. The federal government has therefore established a series of clear AML laws and regulations meant to safeguard the economy by ensuring that banks do not engage in, or facilitate, illegitimate activities.
+
+85. The primary laws governing banks with respect to AML are the Bank Secrecy Act of 1970 ("BSA") and certain provisions of the USA Patriot Act.35
+
+86. Congress enacted the BSA to address an increase in money laundering making its way through financial institutions. Together, the BSA and the Patriot Act create mandatory reporting and record-keeping requirements to track currency transactions and detect and prevent money laundering and the facilitation of other crimes. The law requires banks to maintain compliance programs to prevent, identify, and report suspicious and potentially criminal activity. The BSA and its implementing regulations mandate that banks institute policies, procedures, and controls to protect against money laundering, oversee monitoring with respect to BSA requirements, and test their compliance programs. Each regulated bank "must have a BSA/AML
+
+<sup>34</sup> JP Code of Conduct (2022) at ii., available at https://www.jpmorganchase.com/content/dam/jpmc/jpmorgan-chase-andco/documents/code-of-conduct.pdf.
+
+<sup>35</sup> United Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001(USA-PATRIOT), Pub. L. 107-56.
+
+compliance program commensurate with its respective BSA/AML risk profile."36 And it is the board of directors, "acting through senior management," that is "ultimately responsible for ensuring that the bank maintains an effective BSA/AML internal control structure, including suspicious activity monitoring and reporting."37 Yet policies are not enough; as explained by the Federal Financial Institutions Examinations Counsel—an interagency group of bank regulators—"practices must coincide with the bank's written policies, procedures, and processes."38
+
+# 87. Internal controls should (among other requirements):
+
+- Identify banking operations ... more vulnerable to abuse by money launderers and criminals; provide for periodic updates to the bank's risk profile; and provide for a BSA/AML compliance program tailored to manage risks.
+- Inform the board of directors, or a committee thereof, and senior management, of compliance initiatives, identified compliance deficiencies, and corrective action taken, and notify directors and senior management of [SARs] filed.
+- Implement risk-based [customer due diligence] policies, procedures, and processes.
+- Identify reportable transactions and accurately file all required reports including [SARs], Currency Transaction Reports ("CT Rs"), and CTR exemptions ... [and]
+- Provide sufficient controls and monitoring systems for timely detection and reporting of suspicious activity.39
+
+<sup>36</sup> FFIEC Bank Secrecy Act / Anti-Money Laundering Examination Manual (2006) ("FFIEC Manual"), at 28, available at https://www.ffiec.gov/pdf/bsa\_aml\_examination\_manual2006.pdf.
+
+<sup>37</sup> Id. at 29.
+
+<sup>39</sup> Id.
+
+<sup>39</sup> Id.
+
+88. In addition to the broad requirement for effective, meaningful internal controls, federal law also requires that banks promptly notify authorities upon discovering any suspicious activity. These SARs are "the cornerstone of the BSA reporting system" and are "critical to the United States' ability to utilize financial information to combat terrorist financing, money laundering, and other financial crimes."4° The failure to timely file SARs deprives law enforcement of essential information it needs to combat serious crimes.
+
+89. BSA's implementing regulations, 12 CFR § 21.11 and 12 CFR § 163.180, specify the circumstances under which banks must file a SAR. Section 21.11 provides that banks must file SARs whenever they "detect a known or suspected violation of Federal law."41 More specifically, SARs are required whenever a bank:
+
+detects any known or suspected Federal criminal violation, or pattern of criminal violations . . . involving a transaction or transactions conducted through the bank and involving or aggregating \$5,000 or more in funds or other assets where the bank believes .. . that it was used to facilitate a criminal transaction, and the bank has a substantial basis for identifying a possible suspect . . 42
+
+Similarly, the bank must file a SAR for any transaction conducted through the bank:
+
+aggregating \$5,000 or more in funds or other assets, if the bank knows, suspects, or has reason to suspect that: . . . (ii) The transaction is designed to evade any regulations promulgated under the Bank Secrecy Act; or (iii) the transaction has no business or apparently lawful purpose or is not the sort in which the particular customer would normally be expected to engage, and the institution knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction.43
+
+<sup>4°</sup> Id. at 60.
+
+<sup>41</sup> 12 C.F.R. S 21.11(a).
+
+<sup>42</sup> 12 C.F.R. E. 21.1 1(cX2).
+
+<sup>43</sup> 12 C.F.R. 8 21.1 1(cX4).
+
+90. Notably, SARs must be submitted the finding of suspicious activity. Banks may not avoid filing a SAR simply because they are not certain the activity at issue constitutes a crime.
+
+91. Banks must file any SARs within 30 days "of the initial detection of facts that may constitute a basis for filing a SAR."44 After filing the SAR, management must "promptly notify" the bank's board or a relevant board committee.45 When the suspicious or criminal conduct is ongoing, banks are expected to file a new SAR every 90 days.46
+
+## B. JP BOARD IS OBLIGATED TO ENSURE AND OVERSEE A ROBUST AML PROGRAM
+
+92. JP directors owe fiduciary duties to the Company to conduct adequate oversight to ensure JP and its subsidiaries are not flouting federal laws and regulations. These duties include the duty to develop, implement, and enforce effective internal controls throughout the Company, including with respect to compliance with federal anti-moneylaundering laws and regulations. Federal agencies that supervise the banking industry have repeatedly emphasized the importance of board oversight with respect to BSA/AML compliance.
+
+93. JP primary banking subsidiary, JPMorgan Chase Bank, N.A., is regulated by the OCC.47 OCC-regulated banks are required to "establish and implement a risk governance framework to manage and control the covered bank's risk-taking activities."48 For this purpose,
+
+<sup>&</sup>quot; 12 C.F.R. 8 21.11(d).
+
+<sup>45</sup> 12 C.F.R. 621.11(hX1).
+
+<sup>46</sup> FinCen, The SAR Activity Review (October 2000), at 27, available at https://www.fincen.govisites/default/files/shared/sar tti\_01.pdf.
+
+<sup>47</sup> 12 U.S.C. § 1 et seq.
+
+<sup>48</sup> 12 C.F.R. § Pt. 30, App. D— OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches.
+
+the OCC has established a set of "minimum standards," both for the bank's compliance systems and for its board of directors' oversight. The standards require, among other things, that the board of the bank establish an effective risk governance framework and "actively oversee the [] bank's risk-taking activities and hold management accountable for adhering to the risk governance framework."4°
+
+94. The OCC's Handbook on Corporate and Risk Governance explains that it is the bank's board that is responsible, inter alga, for "providing effective oversight" and for confirming:
+
+- (i) "that the bank has a risk management system, including audit, suitable for the bank's size and activities, and understanding the bank's material risks,"
+- (ii) "that the bank has an effective system of internal controls," and
+- (iii) "that management's actions to correct material weaknesses, including those identified by the bank, its auditors and regulators, are timely and efective."50
+
+95. The Handbook also provides that the bank's board must "oversee the bank's compliance management programs."51 As such, the "OCC expects the board to be responsible for confirming that a system of internal controls is in place."52 Accordingly, the board must "receive information about the effectiveness of the bank's internal controls and information systems" and "demonstrate that it has an adequate understanding of the bank's IT infrastructure, inherent risks,
+
+<sup>49</sup> 12 C.F.R. § Pt. 30, App. D. 6 III(B) (emphasis added).
+
+<sup>5°</sup> Comptroller's Handbook: Corporate and Risk Governance (v2.0, 2019), at 14, available at https://www.occ.gov/publications-and-resources/publications/comptrollershandbooldfiles/corporate-risk-govemance/index-corporate-and-risk-governance.html.
+
+<sup>51</sup> Id. at 56.
+
+<sup>52</sup> Id.
+
+and existing controls."S3 Significantly, the OCC's Handbook confirms that "the sophistication of [a bank's] risk management system should reflect the bank's size, complexity, and risk profile.s54
+
+96. JP itself—the parent entity—is regulated by, among others, the Federal Reserve. Federal Reserve regulations require, among other things, that holding companies like JP M, which have banking subsidiaries, maintain an enterprise-wide risk management program that identifies and manages risk throughout the organization, and that the company's board ensure that the banking subsidiaries have the proper internal controls and risk management systems in place:
+
+One of the primary areas of focus for consolidated supervision of large complex [bank holding companies] is the adequacy of governance provided by the board and senior management. The culture, expectations, and incentives established by the highest levels of corporate leadership set the tone for the entire organization and are essential determinants of whether a banking organization is capable of maintaining fully effective risk management and internal control processes.
+
+97. Further, Regulation YY of the Federal Reserve (12 C.F.R. § 252.33) requires the Board's risk committee approve and review the bank's risk-management policies and oversee the global risk-management framework. The framework "must be commensurate with [the bank's] structure, risk profile, complexity, activities, and size and must include":
+
+- (i) Policies and procedures establishing risk-management governance, risk management procedures, risk-control infrastructure for its global operations; and
+- (ii) Processes and systems for implementing and monitoring compliance with such policies and processes, including:
+  - (A) Processes and systems for identifying and reporting risks and riskmanagement deficiencies, including regarding emerging risks, and ensuring effective and timely implementation of actions to address
+
+<sup>33</sup> Id.
+
+<sup>54</sup> Id. at 35.
+
+emerging risks and risk-management deficiencies for its global operations [and]
+
+- (B) Processes and systems for establishing managerial and employee responsibility for risk management ... ss
+
+98. Board oversight of those systems is imperative, according to the Federal Reserve, because "the board serves a critical role in maintaining the firm's safety and soundness and continued financial and operational resilience of its consolidated operations."56
+
+99. Two standing committees of the Board—the Risk Committee and the Audit Committee—impose additional oversight obligations related to the Company's risk management systems, along with its internal controls.
+
+100. The Risk Committee's purpose, according to its Charter, is "to assist the Board in its oversight of management's responsibility to implement an effective global risk management framework reasonable designed to identify, assess and manage the Firm's strategic, credit and investment, market, and operational risks." The Risk Committee "oversees reputational risks and conduct risks within its scope of responsibility." It is required to receive and review reports from management concerning significant risks, set qualitative and quantitative limits for risk, and approve certain risk policies. The Risk Committee is required to report periodically to the Board concerning any "significant matters" reviewed by the committee.
+
+101. The Risk Committee is also responsible for appointing and replacing the Chief Risk Officer ("CRO"), and setting the Chief Risk Officer's compensation. The Risk Committee must also review the CRO's "proposed priorities, budget and staffing plans annually."
+
+<sup>55</sup> 12 C.F.R. 8 252.33 (a)(2).
+
+<sup>%</sup> SR 21-3/CA21-1: Supervisory Guidance on Board of Directors' Effectiveness, Board of Governors of the Federal Reserve System, available at: https://www.federalreserve.gov/supervisionreg/srletters/SR2 I 03.htm
+
+102. The Audit Committee's purpose, in relevant part, is to "assist the Board in its oversight of . . . [m]anagement's responsibilities to ensure that there is an effective system of controls reasonably designed to: . . . [m]aintain compliance with the corporation's ethical standards, policies, plans and procedures, and with laws and regulations." The Audit Committee "oversees reputational risks and conduct risks within its scope of responsibility . . ."
+
+103. The Charter of the Audit Committee provides that the committee must receive from management—including the Risk and Compliance functions—"communications and presentations," including concerning "significant control issues" and "material weaknesses in the internal control environment." The Audit Committee must also "receive communications and presentations from management summarizing the suspicious activity report filing activity of the Firm and/or its subsidiaries with the appropriate regulatory and law enforcement agencies."
+
+104. By law, regulation, and the Company's own policies, directors had a non-delegable obligation to conduct sufficient, effective oversight to ensure that the bank was operating in compliance with the law. Instead, the Board ignored a series of glaringly obvious indications that Jeffrey Epstein used the bank for years to facilitate a sex trafficking operation and to abuse young women and girls.
+
+## C. THE DIRECTORS FAILED TO RESPOND TO BRIGHT RED FLAGS CONCERNING EPSTEIN'S USE OF THE BANK'S SERVICES TO CONDUCT A CRIMINAL ENTERPRISE
+
+105. Despite the clear obligations of the Company's Board—set forth in federal regulation and in the Company's own policies and committee charters—to ensure that P was conducting its business in compliance with the law, for years the Board sat on its hands as the Bank continued to provide services to disgraced sexual offender Epstein.
+
+106. Since 2006, the directors serving on the Board had knowledge that Epstein was a serial abuser of young women and girls. Even so, the Bank declined to turned him away, choosing instead to rake in fees year after year from servicing the accounts through which he operated the most notorious sex trafficking ring in recent history. The Board also failed to ensure that the Company was meeting its obligations under federal anti-money-laundering laws. Upon information and belief, at no point from 2006 onward did JP submit any SARs concerning Epstein, despite the mounds of evidence available to the Bank that Epstein was using his cash to fund a criminal enterprise and that he was often attempting to structure his transactions to avoid government oversight.
+
+107. As discussed above, from 1998 to 2013, the Company serviced more than 4 dozen accounts for Epstein worth hundreds of millions of dollars, which he used to facilitate his sexual abuse of young girls and women.
+
+108. The Board knew about Epstein's predation no later than 2006. That year, Epstein was arrested and indicted for solicitation of a minor, and the press extensively reported about his abuse of that, and other, victims. The Company's Global Corporate Security Division flagged these press reports, but JP maintained Epstein's account, despite concluding that it should be "classified as high risk" and require special approval.
+
+109. Mary Erdoes, a high-level executive at the Company, admitted in a deposition that the Company knew in 2006 that Epstein abused young girls and paid them in cash. At the same time, JP employees were reporting that Epstein was withdrawing \$80,000 at a time multiple times a month. The Bank was also aware that Epstein pleaded guilty in 2008, was sentenced to serve 18 months in jail, and registered as a sex offender.
+
+110. Despite being aware of Epstein's arrest and guilty plea, and press reports concerning his pedophilia, sexual abuse, and engagement in prostitution, the Bank continued to provide Epstein with banking services for seven more years following his arrest, facilitating his criminal trafficking enterprise. The Bank continued doing business with the disgraced, but wealthy, Epstein, even after Defendant Dimon's purported review of Epstein's account.
+
+III. As discussed further above, revelations continued even after Epstein's guilty plea. In 2011, the Company was made aware of more allegations of human trafficking involving Epstein. But while employees discussed "the situation," they did little more than encourage Staley—Epstein's buddy and co-conspirator—to "discuss" the allegations with him. When Epstein denied the allegations, the Bank continued to do business with him. Later in 2011, the Bank was aware of reports that law enforcement was investigating Epstein for participating in trafficking and molestation of children and that Epstein had settled "a dozen" claims regarding solicitation. Even a senior compliance official warned that there were "Mots of questions" concerning Epstein's behavior. But the Bank refused to cut Epstein off until 2013.
+
+112. The Board was no doubt aware of the mountain of press reports concerning Epstein's conduct, particularly following his very public arrest in 2006. Yet the Board did not take action to terminate the accounts of the ultrawealthy Epstein or cause management to file timely SARs. In failing to ensure that the Bank ceased doing business with the sexual predator, the directors engaged in bad faith, risking liability for the Company and causing untold reputational harm.
+
+113. The obligation to file SARs concerning Epstein's conduct did not cease when the Company finally, and belatedly, terminated Epstein's account in 2013. Yet it appears that the Bank continued to fail to submit such reports to authorities from 2013 until at least 2019. Directors
+
+on the Board during this period continued to be responsible for ensuring that the Bank met its legal obligations, including the obligation to file reports concerning the criminal activity in which Epstein engaged while he maintained a banking relationship with JP . By failing to ensure that the Bank complied with federal laws concerning suspicious transactions and transactions potentially implicating criminal activity, Defendants acted in bad faith and breached their fiduciary duties to the Company.57
+
+### D. THE COMPANY HAD A TROUBLING HISTORY OF FAILING TO COMPLY WITH BSA/AML REGULATIONS AND THE BOARD SHOULD HAVE EXERCISED HEIGHTENED DILIGENCE
+
+114. Furthermore, no later than January 2013, the Board was fully aware of weaknesses in JP AML program and should have exercised heightened diligence conducting oversight. On January 14, 2013, the Company's main banking subsidiary, JP Chase, N.A., entered into a consent order with the OCC (the "2013 OCC Consent Order") because the regulator had "identified deficiencies in the Bank's overall program for Bank Secrecy Act/Anti-Money Laundering ('BSA/AML') compliance ... " More specifically, JP had failed to correct a previously identified problem and BSA/AML compliance violation, and had also violated regulations concerning suspicious activity reports.
+
+115. According to the OCC, -[t]he Bank has failed to adopt and implement a compliance program that adequately covers the required BSA/AML program elements due to an inadequate
+
+<sup>57</sup> Indeed, it was just this type of failure with respect to Epstein—i.e., a failure to investigate Epstein's banking activities and to report Epstein's suspicious transactions—that led Deutsche Bank to being hit with a \$150 million penalty by the N.Y. State Department of Financial Services. The regulator noted that the fact that Epstein's cash withdraws "were suspicious should have been obvious to Bank personnel at various levels. [Deutsche Bank's] failure to recognize this risk constitutes a major compliance failure."
+
+system of internal controls, and ineffective independent testing." Notably, the bank58 had failed to "develop adequate due diligence on customers, particularly in the Commercial and Business Banking Unit, a repeat problem, and failed to file all necessary Suspicious Activity Reports (`SARs') related to suspicious customer activity." The bank had also failed to remedy weaknesses in "the effectiveness of monitoring in light of the customers' cash activity and business type..."
+
+116. According to the OCC, JP had "an inadequate system of internal controls and independent testing, "systemic deficiencies in its transaction monitoring systems [and] due diligence processes . .." The regulator also noted that the bank had "significant shortcomings in SAR decision-making protocols and an ineffective method for ensuring that referrals and alerts are properly documented, tracked, and resolved." In violation of federal regulations, the bank "failed to identify significant volumes of suspicious activity and filed the required SARs concerning suspicious customer activities . . ." As a result of the 2013 OCC Consent Order, the bank was required to take a series of remedial steps, including evaluating its systems for monitoring transactions and filing suspicious activity reports. It was also required to refresh its risk assessments, at least every year. In addition, the bank was required to conduct a SAR look-back to determine "whether additional SARs should be filed on additional subjects or for continuing suspicious activity."
+
+117. The 2013 OCC Consent Order was approved by the bank's board and executed by both Defendants Crown and Dimon, on behalf of JPMorgan Chase Bank, N.A.
+
+118. Just as the OCC had done with respect to the Company's banking subsidiary, JPMorgan Case, N.A., the Federal Reserve issued a Consent Order against the Company itself in
+
+<sup>58</sup> Because the OCC orders discussed in this section deal specifically with JP Chase, N.A., references to the "bank" in this section are to this subsidiary, rather than to the parent entity, JP (as defined above).
+
+January 2013 (the "2013 Federal Reserve Order"). The 2013 Federal Reserve Order required the Board to submit a plan to improve the Company's "firmwide compliance risk management program with regard to compliance with BSA/AML Requirements." In the plan, the Board was required to address funding for a sufficient compliance program, policies to ensure risks are timely identified and managed, and measures to improve the Company's policies, procedures and standards. The Company was also required to review and address the "policies, procedures, and processes" for "identifying and investigating suspicious activity, and for filing suspicious activity reports" and "customer due diligence that consolidates information" on each customer.
+
+119. Because JP BSA/AML systems continued to be deficient, in January 2014 the OCC issued a Consent Order of the Assessment of a Civil Money Penalty (the "2014 OCC Penalty Order"). The 2014 OCC Penalty Order indicated that the regulator had discovered "additional deficiencies in the Bank's BSA/AML compliance program." In particular, the OCC determined that the bank continued to fail to remedy previously identified problems with its BSA/AML compliance program and continued to violate regulations concerning SARs.
+
+120. The OCC determined that, as in 2013, the bank's BSA/AML program remained deficient and the Bank had failed to "develop adequate due diligence on customers" and to "file all necessary SARs related to suspicious customer activity." The bank "failed to correct previously identified systemic weaknesses" concerning customer due diligence and transaction monitoring. More specifically, the bank continued to have "significant shortcomings in SAR decision-making protocols and an ineffective method for ensuring that referrals and alerts [were] properly documented, tracked, and resolved," and "failed to identify significant volumes of suspicious activity and file the required SARs ..."
+
+121. As a result of these failures, the OCC ordered JP to pay \$350 million in a civil money penalty.
+
+122. The 2014 Penalty Order was approved by the bank's board and was executed by Defendants Crown, , and Weldon.
+
+123. On January 7, 2014, the bank entered into a Deferred Prosecution Agreement (the "DPA") with the U.S. Attorney's Office for the Southern District of New York. In the DPA, the bank admitted that it had failed to file SARs concerning the activities of another extraordinarily wealthy banking client, Bernie Madoff. In the DPA, the bank pleaded guilty to two felony counts of failing to maintain an effective anti-money laundering program and failing to file a suspicious activity report.
+
+124. The 2013 OCC Consent Order remained in effect until May 2019, and the 2013 Federal Reserve order remained in effect until December 2019.
+
+125. Because the bank had pleaded guilty to two felonies and paid \$350 million in penalties relating to its failures to file suspicious activity reports and other BSA/AML deficiencies, the Board was no doubt aware that the Company's risk management systems—particularly with respect to SARs—required additional oversight and diligence. Even so, in the years following the consent orders, upon information and belief, the Company continued to fail to file SAR reports concerning the transactions Epstein had conducted with the bank while his account was open.
+
+# E THE BOARD FAILED TO PURSUE CLAIMS AGAINST STALEY
+
+126. The Board also failed to pursue claims against Staley until March 8, 2023. Staley was the CEO of JP Asset Management line of business from 2001 to 2009, and then became the CEO of the Corporate and Investment Banking line of business in 2009 until he left the Company in 2013.
+
+127. The evidence of Staley's involvement with Epstein was clear. See 1174-80, supra. Staley was close friends with Epstein and knew about his sexual predation of young women and girls. According to Doe, Staley "personally observed Doe as a sex trafficking and abuse victim at times including through his departure from JP in 2013."59 He also met with young girls while visiting with Epstein. Staley is also credibly accused of using "aggressive force in his sexual assault" of plaintiff Doe.6°
+
+128. Despite the clear evidence of Staley advocating on behalf of Epstein to maintain his Company accounts, despite having access to over 1,200 emails sent from Staley's JP company account to Epstein which raised questions about Staley's possible involvement in Epstein's criminal enterprise, and despite press reports making clear the close relationship between Epstein and Staley, the Director Defendants failed to pursue claims against Staley until March 2023. At that time, the Company filed claims against him, including for breaching his fiduciary duty and violating the "faithless servant doctrine." By failing to act in a timely fashion, the Board has risked the viability of the claim by subjecting it to a potential statute of limitations defense. Indeed, in his April 24, 2023 Motion to Dismiss in the lawsuit JP belatedly brought against Staley, Staley has argued that those claims are time-barred.6'
+
+# VI. THE OFFICER DEFENDANTS BREACHED THEIR FIDUCIARY DUTIES
+
+129. Officers of Delaware corporations, like directors, have fiduciary duties to the companies, including the duties of good faith and due care. Officers' duty of good faith includes
+
+<sup>&</sup>quot; Doe Complaint.1115.
+
+<sup>6°</sup>Doe Complaint, 1107.
+
+b1 Jane Doe 1 v. JP Chase Bank, N.A., 22-cv-10019 (JSR) Third-Party Def. James Staley's Mem. of Law in Supp. of Mot. to Dismiss, at 18-20, DKT 91.
+
+an obligation to conduct adequate oversight. Officers are required to "make a good faith effort to ensure that information systems are in place" so that "officers receive relevant and timely information that they can provide to the directors."62 Officers must also act on red flags of which they are aware, as they are "optimally positioned to identify red flags and either address them or report upward to more senior officers or to the board. "63
+
+130. Officers of banking entities have specific obligations when it comes to protecting the companies from risk, including BSA/AML risk. The OCC's Comptroller's Handbook explains that the "OCC expects senior management to be responsible for developing and maintaining the risk governance framework and system of internal controls, which enables management to effectively identify, measure, monitor, control, and report risk exposures consistent with the boardestablished risk appetite."64 Moreover, the "CEO and his or her senior management team should be responsible for," among other things, "complying with laws, regulations, and internal bank policies, including policies governing ethics and insider activities," developing and administering a risk governance framework that enables management to effectively identify, measure, monitor, and control risk," and "establishing and maintaining an effective system of internal controls."
+
+131. JP policies spell out in particular the obligations of the Chief Risk Officer ("CRO") of the Company. The CRO is required to attend meetings of the Board's Risk Committee and to discuss with the committee "any concerns that they reasonably believe could be material to the Firm or to a line of business," including any "actions that have been or are planned to be taken
+
+<sup>62</sup> In re McDonald's Corp. S'holder Derivative Litig., 289 A.3d 343, 361 (Del. Ch. 2023).
+
+<sup>63</sup> Id. at 362.
+
+<sup>&</sup>quot; OCC Comptroller's Handbook: Corporate and Risk Governance (v2, July 2019), at 56, available at https://www.occ.gov/publications-and-resources/publications/comptrollershandbookffiles/corporate-risk-governancedindex-corporate-and-risk-governance.html.
+
+to address such concerns." Between meetings, the CRO must "promptly report" any such issues to the Risk Committee's Chair. The CRO also has full access to communications with and report to the Audit Committee "on any matter relevant to risk and compliance."
+
+132. Despite their obligations under federal banking laws and regulations, and the Company's own policies, the Officer Defendants failed to fulfill their fiduciary obligations of due care and oversight. Like the Director Defendants, the Officer Defendants ignored the glaring red flags concerning the Company's complicity in a criminal sex trafficking scheme, including repeated news reports concerning Epstein's involvement in the abuse of girls and young women.
+
+133. The Officer Defendants—including Defendants Bacon, Hogan, and Zubrow (JP CROs)-failed to ensure that the Company was following the law and its own policies with respect to the AML compliance. According to an investigation by the U.S. Virgin Islands government, "it does not appear .. . that JP engaged in any investigation of the source of Epstein's funds."65 Likewise, the Company also "seemingly did no due diligence on the nature of the various business entities for which it held accounts for Epstein, which appear to have no legitimate business purpose and, upon information and belief, were part of Epstein's criminal enterprise in the Virgin Islands.""
+
+134. The Officer Defendants also failed to ensure that SARs were timely filed concerning Epstein's banking activities. A convicted felon and sex offender was able to continue withdraw tens of thousands of dollars in cash every month from the Bank for years, using those funds to abuse young women and girls. When Company employees finally did start to raise alarms—given repeated press reports about Epstein's activities—management did nothing.
+
+ss USVI Complaint, 176.
+
+<sup>66</sup> USVI Complaint,¶77.
+
+Internal discussions resulted in nothing more than Staley—Epstein's buddy—feeling Epstein out and reporting back to other employees that all was well. And a review of Epstein's account that was to be conducted by CEO Dimon either never took place or, if it did, Dimon must have sanctioned the bank's relationship with Epstein, as it was not until 2013—some seven years after Epstein was arrested—that the Bank closed his accounts. Because of the Officer Defendants' failure to act in good faith and with due care, the bank thus helped Epstein prey on vulnerable girls for almost a decade.
+
+# DERIVATIVE ALLEGATIONS AND DEMAND FUTILITY
+
+135. Plaintiff brings this action derivatively on behalf of and for the benefit of JP to redress injuries suffered by the Company as a direct and proximate result of the breaches of fiduciary duty and other legal violations alleged herein. JP in its derivative capacity. is named as defendant solely
+
+136. Plaintiff has owned JP continuously during the time of the wrongful course of conduct constituting the basis for the claims asserted herein.
+
+137. Plaintiff will retain its shares in the Company throughout the duration of this litigation.
+
+138. Plaintiff will adequately and fairly represent the interests of the Company and its stockholders in this litigation and has retained counsel competent and experienced in stockholder derivative actions.
+
+139. The wrongful acts complained of herein subject, and will persist in subjecting, the Company to continuing harm because the adverse consequences of the injurious actions are still in effect and ongoing.
+
+140. Plaintiff repeats and realleges each and every allegation above as if set forth in full herein.
+
+141. Plaintiff has not made a demand on the Board to pursue the claims set forth herein because any pre-suit demand would be futile and is therefore excused as a matter of law.
+
+142. The Demand Board consists of twelve directors: Defendants Dimon, Bammann, , Combs, Crown, Flynn, Hobson, and Neal, as well as non-Defendants Gorsky, Novakovic, and Rometty.
+
+143. A demand on the current Board would be futile because eight of the Demand Board Members—Defendants Dimon, Bammann, =, Combs, Crown, Flynn, Hobson, and Neal—face a substantial risk of liability for acting in bad faith by knowingly or recklessly permitting the Company to continue to serve as a banker for Epstein's criminal enterprise and for failing to ensure that JP operated in compliance with federal law and Company policy concerning the timely filing of SARs.
+
+144. Each of the Defendant Demand Board members either served on the Board during the time that Epstein maintained his accounts at JP used them to conduct his sex trafficking scheme (i.e., Defendants Dimon, =, Crown, and Flynn) and/or served on the Board during the time in which JP was obligated, but failed, to submit SARs regarding Epstein's transactions with the bank (i.e., Defendants Dimon, =, Combs, Crown, Flynn, Hobson, and Neal).
+
+145. Defendants on the Board at the time of the OCC orders face additional risk because they were not only aware of Epstein's conduct, but they were also serving at the time the Company was sanctioned because of its history of failing to comply with AML rules, including rules concerning SARs. Defendants Dimon, Bammann, =, Crown, and Flynn were each on the
+
+Board at the time one or more of the regulators' orders were issued. Moreover, Defendants Dimon and Crown both executed the 2013 OCC Consent Order, which established that the Company had deficiencies in its BSA/AML compliance program in violation of federal law and regulations. Despite being fully cognizant of the weakness in the Company's AML program, Defendants failed to act to ensure that timely reports were filed concerning Epstein's conduct.
+
+146. Defendant Dimon, in particular, faces a substantial risk of liability. He has been the Company's CEO since 2006 and Chairman since 2007, even before Epstein was arrested. He also either failed to review the Epstein accounts over which Company employees had raised concerns or, having reviewed them, failed to act to close the predator off from his funds. He also failed to ensure that his management team effectively supervised the Company's BSA/AML compliance system.
+
+147. Defendant Bammann also has an increased risk of liability as she, in particular, should have been alert to federal requirements concerning an effective BSA/AML program and to the Company's deficiencies in meeting those standards. When public reports emerged about Epstein's criminal conduct, Bammann should have taken action to ascertain the Company's involvement with Epstein, close his accounts, and file timely SARs. After all, before joining the Board, and during the time that Epstein maintained his accounts at the bank, Bammann served as Deputy Head of Risk Management for JP Chase, N.A., and before that, as Chief Risk Management Officer at Bank One. Indeed, in encouraging shareholders to support her Board nomination, the Company touted her "extensive expertise in risk management and regulatory issues."°
+
+<sup>67</sup> JPMorgan Chase & Co., Schedule 14A (2015) at 11.
+
+148. Thus, any lawsuit initiated to remedy the wrongs complained of herein would expose at least eight of the twelve current Board members to significant personal liability for their bad faith breaches of fiduciary duties and other misconduct.
+
+149. The Demand Board members also suffer from a lack of independence from Defendant Dimon. The Demand Board directors have demonstrated their lack of independence by choosing to pursue its belated claims only against Staley, choosing to pin all of the Defendants' failures on him and to avoid implicating Dimon in JP misconduct concerning Epstein. In contrast, an independent Board would have promptly pursued claims against all of those individuals—including directors and former directors—who failed to implement and oversee an effective BSA/AML system and ignored waving red flags. Rather that aggressively pursuing claims against all involved officers, the Demand Board "circled the wagons" by seeking to tag only an executive that conveniently no longer works for JP
+
+150. In addition, Defendant Bammann is conflicted because she is a former Company executive and worked closely with and for Defendant Dimon. She served under, and reported to, Defendant Dimon at Bank One from 2000-2004, where he publicly praised her contributions; she followed Dimon to the Company when it acquired Bank One, and worked for him until the end of 2005, later returning to the Company to join the Board in 2013. As a spokesman for institutional investor CtW Investment Group noted, Bammann was too close to Dimon, and lbjringing in someone who is a former deputy of Jamie Dimon's is absolutely the wrong move." With her close ties to the man under whom she served for half a decade, Bammann could not reasonably be expected to pursue litigation against Defendant Dimon.
+
+151. For the foregoing masons, at least eight of the twelve members of the Demand Board are incapable of impartially considering a litigation demand against the Defendants, and demand is therefore excused as futile.
+
+### CLAIMS FOR RELIEF
+
+#### COUNT I
+
+### Breach Of Fiduciary Duty (Against The Director Defendants)
+
+152. Plaintiff repeats and realleges each and every allegation above as if set forth in full herein.
+
+153. The Director Defendants, as current and former directors of JP M, all owed and owe and owe fiduciary duties to JP and its stockholders. By reason of their fiduciary relationships, the Director Defendants specifically owed and owe JP the highest obligation of good faith and loyalty in the administration of the affairs of the Company, including, without limitation, the oversight of JP compliance with the BSA and regulations promulgated thereunder, and laws and regulations governing AML requirements.
+
+154. In addition, the Director Defendants owed and owe specific fiduciary duties as defined by the Company's corporate governance documents, including the charters of various Board committees (including, but not limited to, those of the Audit and Risk Policy Committees) that, had they been discharged in accordance with the Director Defendants' obligations, would have necessarily prevented the misconduct and the consequent harm to the Company alleged herein.
+
+155. The Director Defendants consciously breached their fiduciary duties and violated their corporate responsibilities by affirmatively and repeatedly ignoring red flags related to Epstein's criminal activity and Epstein's criminal use of his accounts and funds at JP
+
+156. As a direct and proximate result of the Director Defendants' conscious failure to perform their fiduciary duties and exercise their oversight responsibility, JP has sustained, and will continue to sustain, significant damages—both financially and to its corporate image and goodwill. Such damages to JP caused by the Director Defendants include and will include, substantial penalties, fines, damages awards, settlements, expenses, increased regulatory scrutiny, reputational harm, and other liabilities described herein.
+
+157. As a result of the misconduct alleged herein, the Director Defendants are liable to the Company.
+
+## COUNT II
+
+#### Breach Of Fiduciary Duty of Loyalty (Against The Officer Defendants)
+
+158. Plaintiff repeats and realleges each and every allegation above as if set forth in full herein.
+
+159. The Officer Defendants, as current and former officers of JP , all owed and owe fiduciary duties to JP and its stockholders. By reason of their fiduciary relationships, the Officer Defendants specifically owed and owe JP the highest obligation of good faith and loyalty in the administration of the affairs of the Company, including, without limitation, the oversight of JP compliance with the BSA and regulations promulgated thereunder, and laws and regulations governing AML requirements.
+
+160. In addition, the Officer Defendants owed and owe specific fiduciary duties as defined by the Company's corporate governance documents that, had they been discharged in accordance with the Officer Defendants' obligations, would have necessarily prevented the misconduct and the consequent harm to the Company alleged herein.
+
+161. The Officer Defendants consciously breached their fiduciary duties and violated their corporate responsibilities by affirmatively and repeatedly ignoring red flags related to Epstein's criminal activity and Epstein's criminal use of his accounts and funds at JP
+
+162. As a direct and proximate result of the Officer Defendants' conscious failure to perform their fiduciary duties and exercise their oversight responsibility, JP has sustained, and will continue to sustain, significant damages—both financially and to its corporate image and goodwill. Such damages to JP caused by the Officer Defendants include and will include, substantial penalties, fines, damages awards, settlements, expenses, increased regulatory scrutiny, reputational harm, and other liabilities described herein.
+
+163. As a result of the misconduct alleged herein, the Officer Defendants are liable to the Company.
+
+## COUNT III
+
+## Breach Of Fiduciary Duty of Care (Against The Officer Defendants)
+
+164. Plaintiff repeats and re-alleges each and every allegation above as if set forth in full herein.
+
+165. The Officer Defendants, as current and former officers of JP , all owed and owe fiduciary duties to JP and its stockholders. By reason of their fiduciary relationships, the Officer Defendants specifically owed and owe JP the highest obligation of due care in the administration of the affairs of the Company, including, without limitation, ensuring JP compliance with the BSA and regulations promulgated thereunder, and laws and regulations governing AML requirements.
+
+166. In addition, the Officer Defendants owed and owe specific fiduciary duties as defined by the Company's corporate governance documents that, had they been discharged in accordance with the Officer Defendants' obligations, would have necessarily prevented the misconduct and the consequent harm to the Company alleged herein.
+
+167. The Officer Defendants consciously breached their fiduciary duties and violated their corporate responsibilities by consistently and repeatedly permitting JP to breach or fail to comply with its legal and regulatory reporting and compliance requirements related to Epstein's criminal activity and Epstein's criminal use of his accounts and funds at JP
+
+168. As a direct and proximate result of the Officer Defendants' failure to perform their fiduciary duties, JP has sustained, and will continue to sustain, significant damages—both financially and to its corporate image and goodwill. Such damages to JP caused by the Officer Defendants include and will include, substantial penalties, fines, damages awards, settlements, expenses, increased regulatory scrutiny, reputational harm, and other liabilities described herein.
+
+169. As a result of the misconduct alleged herein, the Officer Defendants are liable to the Company.
+
+## RELIEF REQUESTED
+
+WHEREFORE, Plaintiff, on behalf of JP requests judgment as follows:
+
+A. Determining that this action is a proper derivative action maintainable under the law and that demand on the JP Board is excused as futile;
+
+B. Finding the Director Defendants liable for breaching their fiduciary duties by consciously allowing JP to not comply with its reporting obligations under various laws and regulations related to Epstein's criminal conduct and Epstein's use of JP accounts and funds to further his criminal conduct;
+
+C. Finding the Officer Defendants liable for breaching their fiduciary duty by consciously allowing JP to not comply with its reporting obligations under various laws and regulations related to Epstein's criminal conduct and Epstein's use of JP accounts and funds to further his criminal conduct;
+
+D. Finding the Officer Defendants liable for breaching their fiduciary duty by allowing JP to not comply with its reporting obligations under various laws and regulations related to Epstein's criminal conduct and Epstein's use of JP accounts and funds to further his criminal conduct;
+
+E. Directing JP to take all necessary actions to reform and improve its compliance procedures and governance policies to comply with applicable laws and to protect JP and its stockholders from a repeat of the damaging events described herein;
+
+F. Awarding to JP restitution from the Individual Defendants, and each of them, and ordering disgorgement of all profits, benefits, and other compensation obtained by the Individual Defendants;
+
+G. Awarding to Plaintiff the costs and disbursements of the action, including reasonable attorneys' fees, accountants' consultants' and experts' fees, costs, and expenses; and
+
+H. Granting such other and further relief as the Court deems just and proper.
+
+# Dated: May 9, 2023 GRANT & EISENHOFER P.A.
+
+s/ Rebecca Musarra
+
+Rebecca A. Musarra 485 Lexington Ave., 29th Floor New York, NY 10017 rmusarra@gelaw.com (646) 722-8500
+
+Michael J. Barry (pro hac forthcoming) Christine M. Mackintosh (pro hac forthcoming)
+
+Vivek Upadhya (pro hac forthcoming) 123 Justison St. Wilmington DE 19801 mbarry@gelaw.com cmackintosh@gelaw.com vupadhya@gelaw.com (302) 622-7000
+
+Counsel for Plaintiff
+
+**VERIFICATION**
+
+I, M. Scott [REDACTED], Trustee for the Operating Engineers Construction Industry and Miscellaneous Pension Fund (the "Operating Engineers"), hereby verify that the Operating Engineers have held [REDACTED] in JPMorgan Chase & Co. ("JP [REDACTED]" or the "Company"), at all relevant times herein. The Operating Engineers are ready, willing, and able to pursue this stockholder derivative action on behalf of and for the benefit of JP [REDACTED]. I have reviewed the allegations in the attached Verified Stockholder Derivative Complaint, and as to those allegations of which I have personal knowledge, I know those allegations to be true, accurate, and complete. As to those allegations of which I do not have personal knowledge, I rely on my counsel and their investigation, and for that reason I believe them to be true. Having received a copy of the Verified Stockholder Derivative Complaint, and having reviewed it with my counsel, I hereby authorize its filing.
+
+I declare under penalty of perjury that the foregoing is true and correct.
+
+Executed on:
+
+May 8, 2023
+
+![]()M. Scott [REDACTED], Administrator  
+Operating Engineers Construction Industry  
+and Miscellaneous Pension Fund
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02822786/EFTA02822786.md b/marker2/court-pension-v-dimon/EFTA02822786/EFTA02822786.md
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+10/01/2020 The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law. except as prowled by local rules of court. This form. approved by the Judicial Conference of the United States in September 1974, ts required for use of the Clerk of Court for the purpose of inibating the ovil docket sheet.
+
+PLAINTIFFS DEFENDANTS OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND, derivatively on behalf of JPMORGAN CHASE 8 CO.
+
+ATTORNEYS (FIRM NAME. ADDRESS. AND TELEPHONE NUMBER Christine M. Mackintosh.Rebecca A. Musarra. Vivek Upadhya. Grant 8 Eisenhofer. P.A.. 123 Justison Street. Wilmington. DE 19801. (302) 622-7000
+
+### CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE) (00 NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
+
+28 U.S.C. § 1332; 28 U.S.C. § 1367(a)
+
+Dimon, et al. (see seperate sheet for additional defendants)
+
+ATTORNEYS (IF KNOWN)
+
+Has this action, case, or proceeding, or one essentially the same been previously filed in SONY at any time? NoElYesO Judge Previously Assigned
+
+If yes, was this case Vol. O Invol. O Dismissed. No O Yes O If yes, give date 8 Case No.
+
+Is THIS AN INTIRNATIONAL ARSITINDON CASH No Q Yes ❑
+
+## (PLACE AN 14 IN ONE BOX ONLY)
+
+| TORTS                  |                                       | PERSONAL INJURY |                                     | PERSONAL INJURY         |                          | FORFEITURE/PENALTY       |                                         | BANKRUPTCY |                                     | OTHER STATUTES |                         |
+|------------------------|---------------------------------------|-----------------|-------------------------------------|-------------------------|--------------------------|--------------------------|-----------------------------------------|------------|-------------------------------------|----------------|-------------------------|
+| CONTRACT               |                                       | PERSONAL INJURY |                                     | PERSONAL INJURY         |                          | FORFEITURE/PENALTY       |                                         | BANKRUPTCY |                                     | OTHER STATUTES |                         |
+| [ ] 110                | INSURANCE                             | [ ] 310         | AIRPLANE                            | [ ] 367                 | HEALTHCARE/              | [ ] 625                  | DRUG RELATED                            | [ ] 422    | APPEAL                              | [ ] 375        | FALSE CLAIMS            |
+| [ ] 120                | MARINE                                | [ ] 315         | AIRPLANE PRODUCT                    | PHARMACEUTICAL PERSONAL | INJURY/PRODUCT LIABILITY | [ ] 625                  | DRUG RELATED                            | [ ] 422    | APPEAL                              | [ ] 376        | QUI TAM                 |
+| [ ] 130                | [ ] 130                               | [ ] 320         | ASSAULT, LIBEL & SLANDER            | PERSONAL INJURY         | [ ] 365                  | SEIZURE OF PROPERTY      | [ ] 423                                 | WITHDRAWAL | [ ] 400                             | STATE          |                         |
+| [ ] 140                | NEGOTIABLE INSTRUMENT                 | [ ] 330         | FEDERAL EMPLOYERS' LIABILITY        | PRODUCT LIABILITY       | [ ] 368                  | ABSESTOS PERSONAL INJURY | [ ] 690                                 | OTHER      | [ ] REAPPORTIONMENT                 | [ ] 410        | ANTITRUST               |
+| [ ] 150                | RECOVERY OF OVERPAYMENT & ENFORCEMENT | [ ] 340         | MARINE                              | [ ] 350                 | MOTOR VEHICLE            | [ ] 820                  | COPYRIGHTS                              | [ ] 880    | DEFEND TRADE SECRETS ACT            | [ ] 430        | BANKS & BANKING         |
+| [ ] 151                | MEDICARE ACT                          | [ ] 345         | MARINE PRODUCT                      | [ ] 370                 | OTHER FRAUD              | [ ] 830                  | PATENT                                  | [ ] 840    | CONSUMER CREDIT                     | [ ] 470        | RACKETEER INFLU-        |
+| [ ] 152                | RECOVERY OF DEFAULTED                 | [ ] 355         | MOTOR VEHICLE                       | [ ] 371                 | TRUTH IN LENDING         | [ ] 835                  | PATENT-ABBREVIATED NEW DRUG APPLICATION | [ ] 880    | DEFEND TRADE SECRETS ACT            | [ ] 480        | ENCED & CORRUPT         |
+| [ ] 153                | STUDENT LOANS (EXCL VETERANS)         | [ ] 362         | PERSONAL INJURY - MED MALPRACTICE   | [ ] 380                 | OTHER PERSONAL           | [ ] 835                  | PATENT-ABBREVIATED NEW DRUG APPLICATION | [ ] 880    | DEFEND TRADE SECRETS ACT            | [ ] 480        | ORGANIZATION ACT (RICO) |
+| [ ] 160                | STOCKHOLDERS SUITS                    | [ ] 365         | MOTOR VEHICLE                       | [ ] 380                 | OTHER PERSONAL           | [ ] 835                  | PATENT-ABBREVIATED NEW DRUG APPLICATION | [ ] 880    | DEFEND TRADE SECRETS ACT            | [ ] 480        | CONSUMER CREDIT         |
+| [ ] 190                | OTHER CONTRACT                        | [ ] 362         | PERSONAL INJURY - MED MALPRACTICE   | [ ] 380                 | OTHER PERSONAL           | [ ] 710                  | FAIR LABOR                              | [ ] 861    | HIA (1395ff)                        | [ ] 485        | TELEPHONE CONSUMER      |
+| [ ] 195                | CONTRACT                              | [ ] 365         | MOTOR VEHICLE                       | [ ] 385                 | PROPERTY DAMAGE          | [ ] 710                  | FAIR LABOR                              | [ ] 862    | BLACK LUNG (923)                    | [ ] 490        | CABLE/SATELLITE TV      |
+| [ ] 196                | FRANCHISE                             | [ ] 370         | OTHER FRAUD                         | [ ] 385                 | PROPERTY DAMAGE          | [ ] 870                  | STANDARDS ACT                           | [ ] 863    | DIWC/DIWW (405(g))                  | [ ] 850        | SECURITIES/             |
+| ACTIONS UNDER STATUTES |                                       | [ ] 510         | MOTIONS TO                          | [ ] 720                 | LABOR/MGMT               | [ ] 864                  | SSID TITLE XVI                          | [ ] 865    | RSI (405(g))                        | [ ] 850        | COMMODITIES/            |
+| CIVIL RIGHTS           |                                       | [ ] 440         | OTHER CIVIL RIGHTS                  | [ ] 740                 | RAILWAY LABOR ACT        | [ ] 865                  | RSI (405(g))                            | [ ] 890    | OTHER STATUTORY                     | [ ] 890        | ACTIONS                 |
+| REAL PROPERTY          |                                       | [ ] 530         | HABEAS CORPUS                       | [ ] 751                 | FAMILY MEDICAL           | [ ] 870                  | TAXES (U.S. Plaintiff or Defendant)     | [ ] 891    | AGRICULTURAL ACTS                   | [ ] 893        | ENVIRONMENTAL           |
+| [ ] 210                | LAND CONDEMNATION                     | [ ] 535         | DEATH PENALTY                       | [ ] 791                 | LEAVE ACT (FMLA)         | [ ] 871                  | IRS-THIRD PARTY                         | [ ] 870    | TAXES (U.S. Plaintiff or Defendant) | [ ] 891        | MATTERS                 |
+| [ ] 220                | FORECLOSURE                           | [ ] 540         | MANDAMUS & OTHER                    | [ ] 790                 | OTHER LABOR              | [ ] 791                  | EMPL RET INC                            | [ ] 870    | TAXES (U.S. Plaintiff or Defendant) | [ ] 895        | FREEDOM OF              |
+| [ ] 230                | RENT LEASE & EJECTMENT                | [ ] 440         | OTHER CIVIL RIGHTS                  | [ ] 750                 | LITIGATION               | [ ] 791                  | SECURITY ACT (ERISA)                    | [ ] 890    | ARBITRATION                         | [ ] 896        | INFORMATION ACT         |
+| [ ] 240                | TORTS TO LAND                         | [ ] 441         | VOTING                              | [ ] 440                 | OTHER CIVIL RIGHTS       | [ ] 460                  | NATURALIZATION                          | [ ] 895    | AMMINISTRATIVE                      | [ ] 950        | PROCEDURE ACT/REVIEW OR |
+| [ ] 245                | TORT PRODUCT                          | [ ] 445         | AMERICANS WITH DISABILITIES - OTHER | [ ] 550                 | CIVIL RIGHTS             | [ ] 465                  | OTHER IMMIGRATION                       | [ ] 950    | APPEAL OF AGENCY DECISION           | [ ] 950        | STATE STATUTES          |
+| [ ] 248                | LIABILITY                             | [ ] 446         | AMERICANS WITH DISABILITIES - OTHER | [ ] 550                 | CIVIL RIGHTS             | [ ] 465                  | OTHER IMMIGRATION                       | [ ] 950    | APPEAL OF AGENCY DECISION           | [ ] 950        | STATE STATUTES          |
+| [ ] 250                | ALL OTHER                             | [ ] 448         | EDUCATION                           | [ ] 550                 | CIVIL RIGHTS             | [ ] 465                  | OTHER IMMIGRATION                       | [ ] 950    | APPEAL OF AGENCY DECISION           | [ ] 950        | STATE STATUTES          |
+| REAL PROPERTY          |                                       | [ ] 442         | EMPLOYMENT                          | [ ] 550                 | CIVIL RIGHTS             | [ ] 465                  | OTHER IMMIGRATION                       | [ ] 950    | APPEAL OF AGENCY DECISION           | [ ] 950        | STATE STATUTES          |
+| [ ] 210                | LAND CONDEMNATION                     | [ ] 443         | HOUSING/                            | [ ] 550                 | CIVIL RIGHTS             | [ ] 465                  | OTHER IMMIGRATIO                        |            |                                     |                |                         |
+
+## NATURE OF SUIT
+
+Check if demanded in complaint:
+
+CHECK IF THIS IS ACLASS ACTION UNDER F.R.C.P. 23
+
+DEMAND \$ OTHER JUDGE Jed S. Rakoff (22-10019 and, DOCKET NUMBER 22-10904)
+
+DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y. AS DEFINED BY LOCAL RULE FOR DIVISION OF BUSINESS 13? IF SO, STATE:
+
+| <input checked="" type="checkbox"/> 1 Original Proceeding | <input type="checkbox"/> 2 Removed from State Court | <input type="checkbox"/> 3 Remanded from Appellate Court | <input type="checkbox"/> 4 Reinstated or Reopened | <input type="checkbox"/> 5 Transferred from (Specify District)    | <input type="checkbox"/> 6 Multidistrict Litigation (Transferred) | <input type="checkbox"/> 7 Appeal to District Judge from Magistrate Judge |
+|-----------------------------------------------------------|-----------------------------------------------------|----------------------------------------------------------|---------------------------------------------------|-------------------------------------------------------------------|-------------------------------------------------------------------|---------------------------------------------------------------------------|
+| <input type="checkbox"/> a. all parties represented       |                                                     |                                                          |                                                   | <input type="checkbox"/> 8 Multidistrict Litigation (Direct File) |                                                                   |                                                                           |
+| <input type="checkbox"/> b. At least one party is pro se. |                                                     |                                                          |                                                   |                                                                   |                                                                   |                                                                           |
+
+(PLACE AN x IN ONE BOX ONLY)
+
+ 1 U.S. PLAINTIFF  2 U.S. DEFENDANT  3 FEDERAL QUESTION  4 DIVERSITY  
+(U.S. NOT A PARTY)
+
+**IF DIVERSITY, INDICATE CITIZENSHIP BELOW.**
+
+**CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)**
+
+(Place an [X] in one box for Plaintiff and one box for Defendant)
+
+| CITIZEN OF THIS STATE    | PTF [ ] 1 DEF [x] 1 | CITIZEN OR SUBJECT OF A FOREIGN COUNTRY                   | PTF DEF [ ] 3 [ ] 3 | INCORPORATED and PRINCIPAL PLACE OF BUSINESS IN ANOTHER STATE | PTF [ ] 5 DEF [ ] 5 |
+|--------------------------|---------------------|-----------------------------------------------------------|---------------------|---------------------------------------------------------------|---------------------|
+| CITIZEN OF ANOTHER STATE | [x] 2 [x] 2         | INCORPORATED or PRINCIPAL PLACE OF BUSINESS IN THIS STATE | [ ] 4 [ ] 4         | FOREIGN NATION                                                | [ ] 6 [ ] 6         |
+
+PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)
+
+Operating Engineers Construction Industry and Miscellaneous Pension Fund  
+c/o Grant & Eisenhofer P.A.  
+123 Justison Street  
+Wilmington, Delaware 19801
+
+DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)
+
+See separate sheet
+
+DEFENDANT(S) ADDRESS UNKNOWN
+
+REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:
+
+**COURTHOUSE ASSIGNMENT**
+
+I hereby certify that this case should be assigned to the courthouse indicated below pursuant to Local Rule for Division of Business 18, 20 or 21.
+
+Check one: THIS ACTION SHOULD BE ASSIGNED TO:  [ ] PLAINS  MANHATTAN
+
+DATE 05/09/2023 s/ Rebecca A. Musarra  
+SIGNATURE OF ATTORNEY OF RECORD
+
+RECEIPT #
+
+ADMITTED TO PRACTICE IN THIS DISTRICT  
+[ ] NO  
+[x] YES (DATE ADMITTED Mo. 05 Yr. 2010 )  
+Attorney Bar Code # RM3781
+
+Magistrate Judge is to be designated by the Clerk of the Court.
+
+Magistrate Judge \_\_\_\_\_ is so Designated.
+
+## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E. STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW.
+
+Defendants,
+
+and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+Case Number:
+
+# SEPARATE SHEET OF DEFENDANTS/ADDRESSES
+
+James Dimon 1185 Park Ave. Manhattan, NY 10128-1308 New York County
+
+Ashley Bacon 15 Andrews Rd. Greenwich, CT 06830-4711 Fairfield County
+
+Linda B. Bammann 9295 NW Highway 225A Ocala, FL 34482-7348 Marion County
+
+James A. Bell 13800 Mulholland Dr. Beverly Hills, CA 90210-1130 Los Angeles County
+
+John H. Biggs 1 Mcknight Place Apt 251 Saint Louis, MO 63124-1983 St. Louis County
+
+Crandall C. Bowles 1042 Highway 160 W Fort Mill, SC 29715 York County
+
+Stephar 3300 n Dillon, MT 59725-9572 Beaverhead County
+
+Todd A. Combs 206 Fairacres Rd. Omaha, NE 68132-2706 Douglas County
+
+David M. Cote 7869 Route 82 Pine Plains, NY 12567-5265 Dutchess County
+
+James S. Crown 65 E Goethe St. Unit 6NE Chicago, IL 60610-2628 County
+
+Mary Callahan Erdoes 101 20th St. Miami Beach, FL 33139-1903 Miami-Dade County
+
+Timothy P. Flynn 4510 W. Cush Canyon Loop Marana, AZ 85658-4430 Pima County
+
+Ellen V. Futter 79 E 79th St., Unit 2 New York, NY 10075-0202 New York County
+
+Mellody Hobson 800 N Michigan Ave., Apt 4802 Chicago, IL 60611-2155 County
+
+John James Hogan 10620 Gulf Shore Dr. Apt 502 Naples, FL 34108-4036 Collier County
+
+Laban P., Jr. 2261 Central Ave. Harbor Springs, MI 49740-8309 Emmet County
+
+John W. Kessler 220 Market St. Ste 200 New Albany, ■ **43054-9031 Franklin County** 
+
+**Robert I. Lipp 1158 5th Ave., Apt I2A New York, NY 10029-6917 New York County** 
+
+Richard A. Manoogian 15520 Windmill Pointe Dr. Grosse Pointe Park, MI 48230-1857 Wayne County
+
+Michael A. Neal 3510 Fort Charles Dr. Naples, FL 34102-7931 Collier County
+
+David C. Novak 110 Ox Pasture Rd. Southampton, NY 11968-4566 Suffolk County
+
+Lee R. Raymond 1400 Hawthorn Way Westlake, TX 76262-9033 Tarrant County
+
+James E. Staley 930 Park Ave. New York, NY 10028-0209 New York County
+
+William C. Weldon 1264 Lake Worth Ln. North Palm Beach, FL 33408-2905 Palm Beach County
+
+Barry L. Zubrow 1100 S Flagler Dr., Unit 1601 West Palm Beach, FL 33401-6540 Palm Beach County
\ No newline at end of file
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+# United States District Court for the Southern District of New York Related Case Statement
+
+## Full Caption of Later Filed Case:
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND, derivatively on behalf of JPMORGAN CHASE & CO.,
+
+Plaintiff VS. JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. cHN H. BIGGS. CRANDALL C. BOVVLES. STEPHEN B. . TODD A. COMBS. DAVID M. COTE. JAMES S. CROWN. MARY C. ERDOES. TIMOTHY P. FLYNN. ELLEN VS TER, MELLODY HOBSON. JOHN J. HOGAN. LABAN P. a JR.. JOHN W. KESSLER. ROBERT I. LIPP. RICHARD A. MANOOGIAN. MICHAEL A. NEAL. DAVID C. NOVAK. LEE R. RAYMOND. JAMES E. STALEY. WILLIAM C. WELDON. and BARRY L. ZUBROW.
+
+Case Number
+
+1:23-cv-03903
+
+Defendant
+
+# Full Caption of Earlier Filed Case-
+
+(including in bankruptcy appeals the relevant adversary proceeding)
+
+JANE DOE 1, Individually and on Behalf of All Others Similarly Situated,
+
+Plaintiff VS. JPMORGAN CHASE BANK, N.A.,
+
+Case Number
+
+22-cv-10019 (JSR)
+
+Defendant
+
+## Status of Earlier Filed Case:
+
+• (If so, set forth the procedure which resulted in closure, e.g., voluntary Closed dismissal, settlement, court decision. Also, state whether there is an appeal pending.)
+
+Open (If so, set forth procedural status and summarize any court rulings.)
+
+On May 1, 2023, the Court entered an order granting in part and denying in part JP motion to dismiss Doe's First Amended Complaint (Docket #130). The parties are proceeding with certain fact discovery, including the service of document subpoenas and certain depositions scheduled for May 2023.
+
+Explain in detail the reasons for your position that the newly filed case is related to the earlier filed case.
+
+The newly-filed litigation and earlier-filed litigation arise from mmon nucleus of ooerative fact related to Epstein's longstanding history as a client of JP , and JP concealment and/or failure to report Epstein's suspicious banking practices to regulators. The earlier-filed litigation asserts that JP facilitated, concealed, and/or enabled Epstein's abuse of dozens of victims, in violation of New York and federal law. The newlyfiled litigation seeks to hold the board of directors liable for breaching their fiduciary duties by failing to properly oversee JP relationship with Epstein and JP compliance with applicable banking laws and regulations, and thereby allowing JP misconduct related to Epstein to occur.
+
+Signature:
+
+Firm:
+
+s/ Rebecca Musarra Date: 05/09/2023
+
+Grant & Eisenhofer P.A.
+
+# United States District Court for the Southern District of New York Related Case Statement
+
+## Full Caption of Later Filed Case:
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND, derivatively on behalf of JPMORGAN CHASE & CO.,
+
+| Plaintiff                                                                                                                                                                                                                                                                                                                                                                                                                                                | Case Number   |
+|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------|
+| vs.                                                                                                                                                                                                                                                                                                                                                                                                                                                      | 1:23-cv-03903 |
+| <p>JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. [REDACTED], TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FLUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. [REDACTED], JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E. STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,</p> |               |
+
+Defendant
+
+### Full Caption of Earlier Filed Case.
+
+(including in bankruptcy appeals the relevant adversary proceeding)
+
+GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS,
+
+| <span></span>              | <span></span>     |
+|----------------------------|-------------------|
+| Plaintiff                  | Case Number       |
+| vs.                        | 22-cv-10904 (JSR) |
+| JPMORGAN CHASE BANK, N.A., |                   |
+
+Defendant
+
+## Status of Earlier Filed Case:
+
+![](_page_3_Picture_4.jpeg)
+
+• (If so, set forth the procedure which resulted in closure, e.g., voluntary Closed dismissal, settlement, court decision. Also, state whether there is an appeal pending.)
+
+![](_page_3_Picture_7.jpeg)
+
+Open (If so, set forth procedural status and summarize any court rulings.)
+
+On May 8, 2023, the Court issued an order granting in part and denying in part JP motion to dismiss the U.S. Virgin Islands' Second Amended Complaint (Docket #135). The parties are proceeding with certain tact discovery, including the service of document subpoenas and certain depositions scheduled for May 2023.
+
+Explain in detail the reasons for your position that the newly filed case is related to the earlier filed case.
+
+The newly-filed litigation and earlier-filed litigation arise from a commmius of operative fact related to Jeffrey Epstein's longstanding history as a client of JP , and JP concealment of and/or failure to report Epstein's suspicious banking practices to regulators. The earlier-filed litigation asserts that JP facilitated, concealed, and/or enabled Epstein's abuse of Doe 1 and other victims. The newly-filed litigation seeks to hold the board of director f P liable for breaching their fid • ties by failing to properly oversee JP relationship with Epstein and JP compliance with applicable banking laws and regulations, and thereby allowing JP misconduct related to Epstein to occur.
+
+Signature: s/ Rebecca Musarra Date: 05/09/2023 Grant & Eisenhofer P.A.
+
+Firm:
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+## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DEMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E. STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+Defendants,
+
+and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+Case Number: 1:23-cv-3903
+
+Pursuant to Rule 7.1 of the Federal Rules of Civil Procedure, the undersigned counsel of record for plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund certifies the following:
+
+## Part 1
+
+Complete this portion in all cases. Identify any corporate affiliates, subsidiaries, and/or parent corporation and any publicly held corporation owning 10% or more of the of any nongovernmental corporate party or intervenor. If there are no such corporations, the form shall so state.
+
+None
+
+## Part II
+
+Complete this portion only if jurisdiction is based on diversity of citizenship under 28 U.S.C. § 1332(a).
+
+Name and identify the citizenship of every individual or entity whose citizenship is attributed to that party or intervenor for purposes of establishing jurisdiction based upon diversity of citizenship (note: the citizenship of an L.L.C. is the citizenship of each of its members).
+
+Plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund is a citizen of Pennsylvania
+
+Defendant Jamie Dimon is a resident and citizen of the state of New York.
+
+Defendant Ashley Bacon is a resident and citizen of Connecticut.
+
+Defendant Linda B. Bammann is a resident and citizen of the state of Florida.
+
+Defendant James A. Bell is a resident and citizen of the state of California.
+
+Defendant John H. Biggs is a resident and citizen of the state of Missouri.
+
+Defendant Crandall C. Bowles is a resident and citizen of the state of South Carolina.
+
+Defendant Stephen B. is a resident and citizen of the state of Montana.
+
+Defendant Todd A. Combs is a resident and citizen of the state of Nebraska.
+
+Defendant David M. Cote is a resident and citizen of the state of New York.
+
+Defendant James S. Crown is a resident and citizen of the state of Illinois.
+
+Defendant Mary C. Erdoes is a resident and citizen of the state of Florida.
+
+Defendant Timothy P. Flynn is a resident and citizen of the state of Arizona.
+
+Defendant Ellen V. Futter is a resident and citizen of the state of New York.
+
+Defendant Mellody Hobson is a resident and citizen of the state of Illinois.
+
+Defendant John J. Hogan is a resident and citizen of the state of Florida.
+
+Defendant Laban P. , Jr is a resident and citizen of the state of Michigan.
+
+Defendant John W. Kessler is a resident and citizen of the state of Ohio.
+
+Defendant Robert I. Lipp is a resident and citizen of the state of New York.
+
+Defendant Richard A. Manoogian is a resident and citizen of the state of Michigan.
+
+Defendant Michael A. Neal is a resident and citizen of the state of Florida.
+
+Defendant David C. Novak is a resident and citizen of the state of New York.
+
+Defendant Lee R. Raymond is a resident and citizen of the state of Texas.
+
+Defendant James E. Staley is a resident and citizen of the state of New York.
+
+Defendant William C. Weldon is a resident and citizen of the state of Florida.
+
+Defendant Barry L. Zubrow is a resident and citizen of the state of Florida.
+
+Nominal Defendant JPMor an Chase & Co. is a citizen of both Delaware and New York.
+
+Dated: Wilmington, DE May 9, 2023
+
+## GRANT & EISENHOFER P.A.
+
+s/ Rebecca A. Musarra
+
+Rebecca A. Musarra
+
+485 Lexington Ave., 29th Floor
+
+New York, NY 10017
+
+rmusarra@gelaw.com
+
+(646) 722-8500
+
+Michael J. Barry (pro hac forthcoming)
+
+Christine M. Mackintosh (pro hat forthcoming)
+
+Vivek Uphadya (pro hac forthcoming)
+
+123 Justison St.
+
+Wilmington DE 19801
+
+mbarry@gelaw.com cmackintosh@gelaw.com vuphadya@gclaw.com (302) 622-7000 Counsel for Plaintiff
\ No newline at end of file
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+Defendants, and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+correct: I, Christine M. Mackintosh, declare under penalty of perjury that the following is true and
+
+C.A. No. l:23-cv-03903-JSR
+
+## DECLARATION OF CHRISTINE M. MACKINTOSH IN SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE
+
+I. I am counsel with the law firm of Grant & Eisenhofer P.A. I am eligible to practice and a member in good standing in the Commonwealth of Pennsylvania and the state of Delaware. Certificates of Good Standing are appended hereto. I submit this declaration in support of my motion for admission to practice pro hac vice in the above-captioned matter.
+
+- 2. I have not been convicted of a felony.
+- 3. I have not been censured, suspended, disbarred, or denied admission or readmission by any court.
+  - 4. There are no pending disciplinary proceedings against me in any State or Federal
+
+court.
+
+Wherefore Christine M. Mackintosh respectfully submits that she be permitted to appear as counsel and advocate pro hac vice in this one case.
+
+Dated: June 6, 2023
+
+s/ Christine M. Mackintosh
+
+Christine M. Mackintosh
+
+GRANT & EISENHOFER P.A.
+
+123 Justison St.
+
+Wilmington DE 19801
+
+cmalcintosh@gelaw.com
+
+(302) 622-7000
+
+Counsel for Operating Engineers
+
+Construction Industry and Miscellaneous
+
+Pension Fund
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+![](_page_0_Picture_25.jpeg)
+
+Supreme Court of Pennsylvania
+
+**CERTIFICATE OF GOOD STANDING**
+
+***Christine Marie MacKintosh, Esq.***
+
+**DATE OF ADMISSION**
+
+***February 7, 2002***
+
+The above named attorney was duly admitted to the bar of the Commonwealth of Pennsylvania, and is now a qualified member in good standing.
+
+![](_page_0_Picture_32.jpeg)
+
+**Witness my hand and official seal**
+
+**Dated: May 18, 2023**
+
+![]()Patricia A. Johnson  
+Chief Clerk
+
+## SUPREME COURT OF THE STATE OF DELAWARE
+
+## CERTIFICATE OF GOOD STANDING
+
+The Clerk of the Supreme Court of the State of Delaware, the highest Court in the State, certifies that Christine M. Mackintosh was admitted to practice as an attorney in the Courts of this State on December 10, 2007, and is an active member of the Bar of the Supreme Court of the State of Delaware in good standing.
+
+![](_page_1_Picture_4.jpeg)
+
+IN TESTIMONY WHEREOF,
+
+I have hereunto set my hand and affixed the seal of said Court at Dover a-' y of May 2023.
+
+17th all o /17
+
+- Lisa A. Dolph Clerk of the Supreme Court
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. , TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+> Defendants, and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+C.A. No. 1:23-cv-03903-JSR
+
+[PROPOSED] ORDER FOR ADMISSION PRO HAC VICE
+
+The motion of Christine M. Mackintosh for admission to practice pro hac vice in the above-captioned action is GRANTED.
+
+Applicant has declared that she is a member in good standing of the bars of Pennsylvania and Delaware, and that her contact information is as follows:
+
+GRANT & EISENHOFER P.A.
+
+123 Justison St. Wilmington DE 19801 cmackintosh@gelaw.com (302) 622-7000
+
+Applicant having requested admission pro hac vice to appear for all purposes as counsel for plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund in the above-captioned action,
+
+IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned case in the United States District Court for the Southern District of New York.
+
+All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys.
+
+Dated: .2023 New York, NY
+
+> The Honorable Jed S. Rakoff United States District Judge
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+> Defendants, and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+C.A. No. 1:23-cv-03903-JSR
+
+MOTION FOR ADMISSION
+
+PRO HAC VICE
+
+Pursuant to Rule 1.3(c) of the Local Rules of the United States District Courts for the Southern and Eastern Districts of New York, I, Christine M. Mackintosh, hereby move this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund in the above-captioned action.
+
+I am in good standing with the bar of Pennsylvania and Delaware and there are no disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3.
+
+Dated: June 6, 2023 Respectfully submitted,
+
+s/ Christine M. Mackintosh
+
+Christine M. Mackintosh
+
+GRANT & EISENHOFER P.A.
+
+123 Justison St.
+
+Wilmington DE 19801
+
+cmackintosh@gelaw.com
+
+(302) 622-7000
+
+Counsel for Operating Engineers
+
+Construction Industry and Miscellaneous
+
+Pension Fund
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+> Defendants, and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+correct: I, Michael J. Barry, declare under penalty of perjury that the following is true and
+
+C.A. No. l:23-cv-03903-JSR
+
+DECLARATION OF MICHAEL J. BARRY IN SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE
+
+I. I am counsel with the law firm of Grant & Eisenhofer P.A. I am eligible to practice and a member in good standing in the Commonwealth of Pennsylvania, the state of Delaware and the state of New Jersey. Certificates of Good Standing are appended hereto. I
+
+submit this declaration in support of my motion for admission to practice pro hac vice in the above-captioned matter.
+
+- 2. I have not been convicted of a felony.
+- 3. I have not been censured, suspended, disbarred, or denied admission or readmission by any court.
+- 4. There are no pending disciplinary proceedings against me in any State or Federal court.
+
+Wherefore Michael J. Barry respectfully submits that he be permitted to appear as counsel and advocate pro hac vice in this one case.
+
+Dated: June 6, 2023
+
+s/ Michael J. Barry
+
+Michael J. Barry
+
+GRANT & EISENIIOFER P.A.
+
+123 Justison St.
+
+Wilmington DE 19801
+
+mbarry@gelaw.com
+
+(302) 622-7000
+
+Counsel for Operating Engineers
+
+Construction Industry and Miscellaneous
+
+Pension Fund
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+![](_page_0_Picture_1.jpeg)
+
+The above named attorney was duly admitted to the bar of the Commonwealth of Pennsylvania, and is now a qualified member in good standing.
+
+![](_page_0_Picture_8.jpeg)
+
+## SUPREME COURT OF THE STATE OF DELAWARE
+
+### CERTIFICATE OF GOOD STANDING
+
+The Clerk of the Supreme Court of the State of Delaware, the highest Court in the State, certifies that **Michael J. Barry** was admitted to practice as an attorney in the Courts of this State on **December 17, 2002**, and is an **active** member of the Bar of the Supreme Court of the State of Delaware in good standing.
+
+![](_page_1_Picture_66.jpeg)
+
+**IN TESTIMONY WHEREOF,**
+
+I have hereunto set my hand and affixed the seal of said Court at Dover this 17<sup>th</sup> day of May 2023.
+
+![]()Lisa A. Dolph  
+Clerk of the Supreme Court
+
+# Supreme Court of New Jersey
+
+![](_page_2_Picture_103.jpeg)
+
+## Certificate of Good Standing
+
+This is to certify that **Michael James Barry**  
+(No. **041551993**) was constituted and appointed an Attorney at Law of New Jersey on **December 21, 1993** and, as such, has been admitted to practice before the Supreme Court and all other courts of this State as an Attorney at Law, according to its laws, rules, and customs.
+
+I further certify that as of this date, the above-named is an Attorney at Law in Good Standing. For the purpose of this Certificate, an attorney is in "Good Standing" if the Court's records reflect that the attorney: 1) is current with all assessments imposed as a part of the filing of the annual Attorney Registration Statement, including, but not limited to, all obligations to the New Jersey Lawyers' Fund for Client Protection; 2) is not suspended or disbarred from the practice of law; 3) has not resigned from the Bar of this State; and 4) has not been transferred to Disability Inactive status pursuant to Rule 1:20-12.
+
+Please note that this Certificate does not constitute confirmation of an attorney's satisfaction of the administrative requirements of Rule 1:21-1(a) for eligibility to practice law in this State.
+
+![](_page_2_Picture_108.jpeg)
+
+In testimony whereof, I have  
+hereunto set my hand and  
+affixed the Seal of the  
+Supreme Court, at Trenton, this  
+30th day of May, 2023.
+
+![]()
\ No newline at end of file
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. , TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+> Defendants, and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+C.A. No. 1:23-cv-03903-JSR
+
+[PROPOSED] ORDER FOR ADMISSION PRO HAC VICE
+
+The motion of Michael J. Barry for admission to practice pro hac vice in the abovecaptioned action is GRANTED.
+
+Applicant has declared that he is a member in good standing of the bars Pennsylvania, Delaware and New Jersey, and that his contact information is as follows:
+
+GRANT & EISENHOFER P.A.
+
+123 Justison St. Wilmington DE 19801 mbarry@gelaw.com (302) 622-7000
+
+Applicant having requested admission pro hac vice to appear for all purposes as counsel for plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund in the above-captioned action,
+
+IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned case in the United States District Court for the Southern District of New York.
+
+All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys.
+
+Dated: .2023 New York, NY
+
+> The Honorable Jed S. Rakoff United States District Judge
\ No newline at end of file
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+> Defendants, and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+C.A. No. 1:23-cv-03903-JSR
+
+MOTION FOR ADMISSION
+
+PRO HAC VICE
+
+Pursuant to Rule 1.3(c) of the Local Rules of the United States District Courts for the Southern and Eastern Districts of New York, I, Michael J. Barry, hereby move this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund in the above-captioned action.
+
+I am in good standing with the bar of Pennsylvania, Delaware and New Jersey and there are no disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3.
+
+Dated: June 6, 2023 Respectfully submitted,
+
+s/ Michael J. Barry
+
+Michael J. Barry
+
+GRANT & EISENHOFER P.A.
+
+123 Justison St.
+
+Wilmington DE 19801
+
+mbarry@gelaw.com
+
+(302) 622-7000
+
+Counsel for Operating Engineers
+
+Construction Industry and Miscellaneous
+
+Pension Fund
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. , TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+> Defendants, and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+C.A. No. 1:23-cv-03903-JSR
+
+[PROPOSED] ORDER FOR ADMISSION PRO HAC VICE
+
+The motion of Christine M. Mackintosh for admission to practice pro hac vice in the above-captioned action is GRANTED.
+
+Applicant has declared that she is a member in good standing of the bars of Pennsylvania and Delaware, and that her contact information is as follows:
+
+GRANT & EISENHOFER P.A.
+
+123 Justison St. Wilmington DE 19801 cmackintosh@gelaw.com (302) 622-7000
+
+Applicant having requested admission pro hac vice to appear for all purposes as counsel for plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund in the above-captioned action,
+
+IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned case in the United States District Court for the Southern District of New York.
+
+All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys.
+
+Dated: June 9 .2023 New York, NY
+
+The Honorable Jed S. Rakoff United States District Judge
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02822819/EFTA02822819.md b/marker2/court-pension-v-dimon/EFTA02822819/EFTA02822819.md
new file mode 100644
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@@ -0,0 +1,37 @@
+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+> Defendants, and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+C.A. No. 1:23-cv-03903-JSR
+
+[PROPOSED] ORDER FOR ADMISSION PRO HAC VICE
+
+The motion of Michael J. Barry for admission to practice pro hac vice in the abovecaptioned action is GRANTED.
+
+Applicant has declared that he is a member in good standing of the bars Pennsylvania, Delaware and New Jersey, and that his contact information is as follows:
+
+GRANT & EISENHOFER P.A. 123 Justison St. Wilmington DE 19801
+
+mbarry@gelaw.com (302) 622-7000
+
+Applicant having requested admission pro hac vice to appear for all purposes as counsel for plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund in the above-captioned action,
+
+IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned case in the United States District Court for the Southern District of New York.
+
+All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys.
+
+Dated: June 9 .2023 New York, NY
+
+The Honorable Jed S. Rakoff United States District Judge
\ No newline at end of file
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL. JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E. STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+> Defendants, and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+C.A. No. I :23-cv-03903-JSR
+
+NOTICE OF APPEARANCE
+
+## TO THE CLERK OF THIS COURT AND ALL PARTIES OF RECORD:
+
+PLEASE TAKE NOTICE that the undersigned attorney hereby enters his appearance as counsel in this action for Plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund. I certify that I am admitted to practice in this court.
+
+Dated: June 21, 2023 Respectfully submitted,
+
+GRANT & EISENHOFER P.A.
+
+s/ Vivek Cloadhva
+
+Vivek Upadhya 123 Justison St. Wilmington DE 19801 vupadhya@gelaw.com (302) 622-7000
+
+Counsel for Plaintiff
\ No newline at end of file
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+# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+Operating Engineers
+
+-v-
+
+Dimon
+
+Plaintiff(s),
+
+Defendant(s).
+
+# x NOTICE OF COURT CONFERENCE
+
+23cv3903 (JSR)
+
+To: The Attorneys) for Plaintiff(s):
+
+x
+
+USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC # DATE FILED: 6/21/2023
+
+The Honorable Jed S. Rakoff, U.S.D.J. has ordered that counsel for all parties attend a conference, at the time and place fixed below, for the purpose of case management and scheduling pursuant to Fed. R. Civ. P. 16. You are directed to furnish all attorneys in this action with copies of this notice and enclosures, and to furnish with a copy of any transmittal letter(s). If you are unaware of the identity of counsel for any of the parties, you should send a copy of the notice and rules to that party personally, informing the party that any unrepresented party is required to a r at the conference in person. Finally, upon receipt of this notice, please immediately furnish with a courtesy copy of your complaint and F.R.C.P. Rule 7.1 Statement, if applicable.
+
+Since this case has been designated an electronic case, by the date of the initial pretrial conference counsel for all parties are required to register as filing users in accordance NN it h t he Procedures for Electronic Case Filing and file an Notice of Appearance.
+
+DATE AND PLACE OF CONFERENCE: 6/26/2023, ON A TELECONFERENCE LINE AT 11:15am. The dial-in information for the call will be as follows: USA Toll-Free (888) 363-4735; USA Caller Paid/International Toll: (215) 446-3657; Access Code: 1086415.
+
+No application for adjournment will be considered unless made within one week of the date of this notice. The fact that any party has not answered the complaint does not excuse attendance by that party, or warrant any adjournment of the conference.
+
+No later than one week prior to the conference, the parties shall furnish the Court with a written report of their agreements or disagreements regarding planning of discovery pursuant to Fed. Civ. P. 26(f). Enclosed is a form (Form D) for a Case Management Plan that the parties may utilize in making this report. In the absence of agreement, the Court, after hearing from counsel, will order a Case Management Plan and schedule at the conference. Absent extraordinary circumstances, the Plan shall provide that the case be ready for trial within five months of the date of the conference.
+
+In addition to the matters covered in Form D, counsel should also be prepared to address at the conference the factual and legal bases for their claims or defenses, any issue as to subject matter jurisdiction, and any other issue relevant to case management.
+
+SO ORDERED.
+
+tfi d Mk"
+
+JED S. RAKOFF U.S.D.J.
+
+DATED: New York, New York June 21, 2023
+
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+x
+
+#### Operating Engineers
+
+### Plaintiff(s), CIVIL CASE MANAGEMENT PLAN (JUDGE RAKOFF)
+
+-v-
+
+23cv3903 (JSR)
+
+#### Dimon
+
+Defendant(s).
+
+x
+
+This Court requires that this case shall be ready for trial on
+
+11/27/2023.
+
+After consultation with counsel for the parties, the following Case Management Plan is adopted. This plan is also a scheduling order pursuant to Rules 16 and 26(f) of the Federal Rules of Civil Procedure.
+
+- A. The case (is) (is not) to be tried to a jury. [Circle as appropriate]
+- B. Joinder of additional parties must be accomplished by
+- C. Amended pleadings may be filed without leave of Court until
+- D. Discovery (in addition to the disclosures required by Fed. R. Civ. P. 26(a)):
+  - I. Documents. First request for production of documents, if any, must be served by . Further document requests may be served as required, but no document request may be served later than 30 days prior to the date of the close of discovery as set forth in item 6 below.
+  - 2. Interrogatories. Interrogatories pursuant to Rule 33.3(a) of the Local Civil Rules of the Southern District of New York must be served by . No other interrogatories are permitted except upon prior express permission of Judge Rakoff. No Rule 33.3(a) interrogatories need be served with respect to disclosures automatically required by Fed. IL Civ. P. 26(a).
+  - 3. Experts. Every party-proponent of a claim (including any counterclaim, cross-claim, or thirdparty claim) that intends to offer expert testimony in respect of such claim must make the disclosures required by Fed. It Civ. P. 26(a)(2) by . Every party-opponent of such claim that intends to offer expert testimony in opposition to such claim must make the disclosures required by Fed. R. Civ. P. 26(a)(2) by . No expert testimony (whether designated as "rebuttal" or otherwise) will be permitted by other experts or beyond the scope of the opinions covered by the aforesaid disclosures except upon prior express permission of the Court, application for which must be made no later than 10 days after the date specified in the immediately preceding sentence. All experts may be deposed, but such depositions must occur within the time limit for all depositions set forth below.
+
+4. Depositions. All depositions (including any expert depositions, see item 3 above) must be completed by . Unless counsel agree otherwise or the Court so orders, depositions shall not commence until all parties have completed the initial disclosures required by Fed. IL Civ. P. 26(aX1) or until four weeks from the date of this Order, whichever is earlier. Depositions shall proceed concurrently, with no party having priority, and no deposition shall extend beyond one business day without prior leave of the Court.
+
+5. Requests to Admit. Requests to Admit, if any, must be served by [insert date that is no later than 30 days prior to date of close of discovery as set forth in item 6 below].
+
+6. All discovery is to be completed by . Interim deadlines for items 1-5 above may be extended by the parties on consent without application to the Court, provided the parties are certain they can still meet the discovery completion date set forth in this paragraph. The discovery completion date may be adjourned only upon a showing to the Court of extraordinary circumstances, and may not be extended on consent.
+
+E. Post-discovery summary judgment motions in the form prescribed by the Court's Individual Rules of Practice may be brought on without further consultation with the Court provided that a Notice of any such motion, in the form specified in the Court's Individual Rules of Practice, is filed no later than one week following the close-of-discovery date (item D-6 above) and provided that the moving papers are served by , answering papers by , and reply papers by [the last of these days being no later than six weeks following the close of discovery]. Each party must file its respective papers with the Clerk of the Court on the same date that such papers are served. Additionally, on the same date that any papers are served and filed, counsel filing and serving the apers must arrange to deliver courtesy non-electronic hard copies to the Courthouse for delivery to
+
+F. A final pre-trial conference, as well as oral argument on any post-discovery summary judgment motions, shall be held on [date to be inserted by the Court], at which time the Court shall set a firm trial date. The timing and other requirements for the Joint Pretrial Order and/or other pre-trial submissions shall be governed by the Court's Individual Rules of Practice.
+
+G. All motions and applications shall be governed by Judge Rakoff's Individual Rules of Practice. Counsel shall promptly familiarize themselves with all of the Court's Individual Rules, as well as with the Local Rules for the United States District Court for the Southern District of New York.
+
+SO ORDERED.
+
+JED S. RAKOFF
+
+U.S.D.J.
+
+DATED: New York, New York
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diff --git a/marker2/court-pension-v-dimon/EFTA02822826/EFTA02822826.md b/marker2/court-pension-v-dimon/EFTA02822826/EFTA02822826.md
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index 0000000000000000000000000000000000000000..6c52cdabbcdfa7ac42a9cb020669a5d507e017fd
--- /dev/null
+++ b/marker2/court-pension-v-dimon/EFTA02822826/EFTA02822826.md
@@ -0,0 +1,55 @@
+## UNITED STATES DISTRICT COURT
+
+for the
+
+Southern District of New York
+
+Operating Engineers Construction Industry and Miscellaneous Pension Fund
+
+Plaintiff
+
+v.
+
+Dimon et al
+
+Defendant
+
+Case No. 1:23-cv-03903-JSR
+
+## APPEARANCE OF COUNSEL
+
+To: The clerk of court and all parties of record
+
+I am admitted or otherwise authorized to practice in this court, and I appear in this case as counsel for:
+
+Defendants JPMorgan Chase & Co., James Dimon, Ashley Bacon, Mary Callahan Erdoes, John Hogan, and Bany Zubrow
+
+Date: 06/21/2023 /s/ Noah Levine
+
+Attorney's signature
+
+Noah Levine (Bar No. 4324521)
+
+Printed name and bar number
+
+Wilmer Cutler Pickering Hale and Doff LLP
+
+7 World Trade Center
+
+250 Greenwich Street
+
+New York, NY 10007
+
+Address
+
+Noah.Levine@wilmerhale.com
+
+E-mail address
+
+(212) 230-8875
+
+Telephone number
+
+(212) 230-8888
+
+FAX number
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02822827/EFTA02822827.md b/marker2/court-pension-v-dimon/EFTA02822827/EFTA02822827.md
new file mode 100644
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--- /dev/null
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@@ -0,0 +1,55 @@
+## UNITED STATES DISTRICT COURT
+
+Southern District of New York
+
+Operating Engineers Construction Industry and Miscellaneous Pension Fund
+
+for the
+
+) ) ) )
+
+Dimon et al
+
+Plaintiff
+
+V.
+
+Case No. 1:23-cv-03903-JSR
+
+) Defendant
+
+## APPEARANCE OF COUNSEL
+
+To: The clerk of court and all parties of record
+
+I am admitted or otherwise authorized to practice in this court, and I appear in this case as counsel for:
+
+Defendants JPMorgan Chase & Co., James Dimon, Ashley Bacon, Mary Callahan Erdoes, John Hogan, and Barry Zubrow
+
+Date: 06/21/2023 /V Timothy Perla
+
+Attorney's signature
+
+Timothy Perla (Bar No. 4275178)
+
+Printed name and bar number
+
+Wilmer Cutler Pickering Hale and Doff LLP
+
+60 StaktStreet
+
+Boston, 02109
+
+Address
+
+Tlmothv.PerlaQwilmerhale.com
+
+E-mail address
+
+(617) 526-6696
+
+Telephone number
+
+(617) 526-5000
+
+FAX number
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02822828/EFTA02822828.md b/marker2/court-pension-v-dimon/EFTA02822828/EFTA02822828.md
new file mode 100644
index 0000000000000000000000000000000000000000..c01acc4563436e8a722411f175ace32b108b69be
--- /dev/null
+++ b/marker2/court-pension-v-dimon/EFTA02822828/EFTA02822828.md
@@ -0,0 +1,39 @@
+## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E. STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+Defendants.
+
+and
+
+JPMORGAN CHASE & CO.
+
+Nominal Defendant.
+
+Case No. 23-cv-03903-JSR
+
+## NOTICE OF APPEARANCE
+
+PLEASE TAKE NOTICE THAT the undersigned, of the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP, is hereby entering an appearance as counsel of record for Linda B. Bammann, James A. Bell, John H. Biggs, Stephen B. =, Todd A. Combs, David M. Cote, James S. Crown, Timothy P. Flynn, Ellen V. Futter, Mellody Hobson, Laban P. M,
+
+Jr., John W. Kessler, Robert 1. Lipp, Richard A. Manoogian, Michael A. Neal, David C. Novak,
+
+Lee R. Raymond, and William C. Weldon in the above-captioned matter.
+
+Dated: June 22, 2023
+
+New York, NY Respectfully submitted,
+
+PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
+
+By: is/ Audra J. Soloway
+
+Audra J. Soloway
+
+1285 Avenue of the Americas New York, NY 10019 Tel: (212) 373-3000 Fax: (212) 757-3990 asoloway@paulweiss.com
+
+Counsel for Defendants Linda B. Bammann, James A. Bell, John H. Biggs, Stephen B. , Todd A. Combs, David M. Cote, James S. Crown, Timothy P. pF. ..Ellen V. Futter. Mellody Hobson. Laban P. , Jr., John W. Kessler, Robert I. Lipp, Richard A. Manoogian, Michael A. Neal, David C. Novak Lee R. Raymond, and William C. Weldon
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--- /dev/null
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@@ -0,0 +1,39 @@
+## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E. STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+Defendants.
+
+and
+
+JPMORGAN CHASE & CO.
+
+Nominal Defendant.
+
+Case No. 23-cv-03903-JSR
+
+## NOTICE OF APPEARANCE
+
+PLEASE TAKE NOTICE THAT the undersigned, of the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP, is hereby entering an appearance as counsel of record for Linda B. Bammann, James A. Bell, John H. Biggs, Stephen B. =, Todd A. Combs, David M. Cote, James S. Crown, Timothy P. Flynn, Ellen V. Futter, Mellody Hobson, Laban P. M,
+
+Jr., John W. Kessler, Robert 1. Lipp, Richard A. Manoogian, Michael A. Neal, David C. Novak, Lee R. Raymond, and William C. Weldon in the above-captioned matter.
+
+Dated: June 22, 2023
+
+New York, NY Respectfully submitted,
+
+PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
+
+By: /s/ Jessica S. Carey
+
+Jessica S. Carey
+
+1285 Avenue of the Americas New York, NY 10019 Tel: (212) 373-3000 Fax: (212) 757-3990 jcarey@paulweiss.com
+
+Counsel for Defendants Linda B. Bammann, James A. Bell, John H. Biggs, Stephen B. , Todd A. Combs, David At Cote, James S. Crown, Timothy P. Pl i.Ellen V. Futter. Mellody Hobson. Laban P. , Jr., John W. Kessler, Robert I. Lipp, Richard A. Manoogian, Michael A. Neal, David C. Novak Lee R. Raymond, and William C Weldon
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+## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. , TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. I , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E. STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+Defendants.
+
+and
+
+JPMORGAN CHASE & CO.
+
+Nominal Defendant.
+
+Case No. 23-cv-03903-JSR
+
+## NOTICE OF APPEARANCE
+
+PLEASE TAKE NOTICE THAT the undersigned, of the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP, is hereby entering an appearance as counsel of record for Linda B. Bammann, James A. Bell, John H. Biggs, Stephen B. =, Todd A. Combs, David M. Cote, James S. Crown, Timothy P. Flynn, Ellen V. Futter, Mellody Hobson, Laban P. M,
+
+Jr., John W. Kessler, Robert 1. Lipp, Richard A. Manoogian, Michael A. Ncal, David C. Novak, Lee R. Raymond, and William C. Weldon in the above-captioned matter.
+
+Dated: June 22, 2023
+
+New York, NY Respectfully submitted,
+
+PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
+
+By: is/Jacobus J. Schulte Jacobus J. Schutte
+
+1285 Avenue of the Americas New York, NY 10019 Tel: (212) 373-3000 Fax: (212) 757-3990 jschutte@paulweiss.com
+
+Counsel for Defendants Linda B. Bammann, James A. Bell, John H. Biggs, Stephen B. , Todd A. Combs, David M. Cote, James S. Crown, Timothy P. Flynn. 11en V. Futter. Mellody Hobson, Laban P. , Jr., John W. Kessler, Robert I. Lipp, Richard A. Manoogian, Michael A. Neal, David C. Novak Lee R. Raymond, and William C Weldon
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+Revised Form D—For cases assigned to Judge Rakoff
+
+Effective September 10, 2010
+
+UNITED STATES DISTRICT COURT  
+SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS  
+CONSTRUCTION INDUSTRY AND  
+MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+-v-
+
+JAMES DIMON, ASHLEY BACON,  
+LINDA B. BAMMANN, JAMES A. BELL,  
+JOHN H. BIGGS, CRANDALL C.  
+BOWLES, STEPHEN B. [REDACTED], TODD  
+A. COMBS, DAVID M. COTE, JAMES S.  
+CROWN, MARY C. ERDOES, TIMOTHY  
+P. FLYNN, ELLEN V. FUTTER,  
+MELLODY HOBSON, JOHN J. HOGAN,  
+LABAN P. [REDACTED], JR., JOHN W.  
+KESSLER, ROBERT I. LIPP, RICHARD A.  
+MANOOGIAN, MICHAEL A. NEAL,  
+DAVID C. NOVAK, LEE R. RAYMOND,  
+JAMES E. STALEY, WILLIAM C.  
+WELDON, and BARRY L. ZUBROW,
+
+Defendants,
+
+and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+Motion To Dismiss  
+Manager's Papers - 7/6  
+Assessments Papers - 7/20  
+Reply - 7/27
+
+CIVIL CASE MANAGEMENT PLAN  
+(JUDGE RAKOFF)
+
+1:23 Civ. 03903 (JSR)
+
+**This Court requires that this case shall be ready for trial on  
+January 19, 2024.**
+
+After consultation with counsel for the parties, the following Case Management Plan is adopted. This plan is also a scheduling order pursuant to Rules 16 and 26(f) of the Federal Rules of Civil Procedure.
+
+- A. The case (is) (is not) to be tried to a jury.
+- B. Joinder of additional parties must be accomplished by July 14, 2023.
+
+- C. Amended pleadings may be filed without leave of Court until July 14, 2023.
+- D. Defendants shall file any motion to dismiss papers by July 11, 2023. Plaintiff shall file its Opposition by July 28, 2023. Defendants shall file their Reply by August 7, 2023.
+- E. Nominal Defendant JPMorgan Chase & Co. ("JPMorgan") shall exercise best efforts to complete production of categories of documents agreed upon by the Parties by July 7, 2023. Defendants will not produce or participate in any further discovery until the Court issues a ruling on Defendants' motion to dismiss. *on August 3, 2023.*
+
+F. To the extent the Court does not include in the approved Case Management Plan item D above (which provides for limited discovery of agreed upon categories of documents pending a ruling on Defendants' motion to dismiss), Discovery shall proceed as follows (in addition to the disclosures required by Fed. R. Civ. P. 26(a)). Otherwise, a case management conference shall be scheduled within 7 days of the Court's ruling on Defendants' motion to dismiss to set additional deadlines.
+
+1. 1. Documents. First request for production of documents, if any, must be served by July 21, 2023. Further document requests may be served as required, but no document request may be served later than 30 days prior to the date of the close of discovery as set forth in item 6 below.
+2. 2. Interrogatories. Interrogatories pursuant to Rule 33.3(a) of the Local Civil Rules of the Southern District of New York must be served by September 4, 2023. No other interrogatories are permitted except upon prior express permission of Judge Rakoff. No Rule 33.3(a) interrogatories need be served with respect to disclosures automatically required by Fed. R. Civ. P. 26(a).
+3. 3. Experts. Every party-proponent of a claim (including any counterclaim, cross-claim, or third-party claim) that intends to offer expert testimony in respect of such claim must make the disclosures required by Fed. R. Civ. P. 26(a)(2) by October 25, 2023. Every party-opponent of such claim that intends to offer expert testimony in opposition to such claim must make the disclosures required by Fed. R. Civ. P. 26(a)(2) by November 8, 2023. No expert testimony (whether designated as "rebuttal" or otherwise) will be permitted by other experts or beyond the scope of the opinions covered by the aforesaid disclosures except upon prior express permission of the Court, application for which must be made no later than 10 days after the date specified in the immediately preceding sentence. All experts may be deposed, but such depositions must occur within the time limit for all depositions set forth below.
+4. 4. Depositions. All depositions (including any expert depositions, see item 3 above) must be completed by November 22, 2023. Unless counsel agree otherwise or the Court so orders, depositions shall not commence until all parties have completed the initial disclosures required by Fed. R. Civ. P. 26(a)(1) or until four weeks from the date of this Order, whichever is earlier. Depositions shall proceed concurrently, with no party having priority, and no deposition shall extend beyond one business day without prior leave of the Court.
+
+*for 21, 2023*
+
+- 5. Requests to Admit. Requests to Admit, if any, must be served by October 20, 2023.
+- 6. All discovery is to be completed by November 22. 2023. Interim deadlines for items 1-5 above may be extended by the panics on consent without application to the Court, provided the parties are certain they can still meet the discovery completion date set forth in this paragraph. The discovery completion date may be adjourned only upon a showing to the Court of extraordinary circumstances, and may not be extended on consent.
+
+G. Post-discovery summary judgment motions in the form prescribed by the Court's Individual Rules of Practice may be brought on without further consultation with the Court provided that a Notice of any such motion, in the form specified in the Court's Individual Rules of Practice, is filed no later than one week following the close-of-discovery date (item F-6 above/ and provided that the moving papers are served by November 29. 2023, answering papers by December 20. 2023, and reply papers by January 5. 2024. Each party must file its respective papers with the Clerk of the Court on the same date that such papers are served. Additionally, on the same date that any papers are served and filed, counsel filing and serving the papers must aln deliver courtesy non-electronic hard copies to the Courthouse for delivery to
+
+H. A final pre-trial conference, as well as oral argument on any post-discovery summary judgment motions, shall be held on 1 /3 a 9 itht , at which time the Court shall set a firm trial date. The timing and other r uirements for the Joint Pretrial Order and/or other pretrial submissions shall be governed by the Court's Individual Rules of Practice.
+
+1. All motions and applications shall be governed by Judge RakofPs Individual Rules of Practice. Counsel shall promptly familiarize themselves with all of the Court's Individual Rules, as well as with the Local Rules for the United States District Court for the Southern District of New York.
+
+SO ORDERED.
+
+DATED: New York, r rk ca) R.3
+
+`QED 041 cei S. RAKOt U.S.D.J.
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@@ -0,0 +1,1081 @@
+#### UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+CITY OF MIAMI GENERAL EMPLOYEES & SANITATION EMPLOYEES RETIREMENT TRUST
+
+and
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND
+
+Plaintiffs,
+
+v.
+
+JAMES DIMON, STEPHEN B. TODD A. COMBS, JAMES S. CROWN, TIMOTHY P. FLYNN, MELLODY HOBSON, JOHN W. KESSLER, PHEBE N. NOVAKOVIC, and JAMES E. STALEY,
+
+Defendants,
+
+and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+Civil Case No: 1:23-cv-03903
+
+JURY TRIAL DEMANDED
+
+## VERIFIED AMENDED STOCKHOLDER DERIVATIVE COMPLAINT
+
+Plaintiff City of Miami General Employees & Sanitation Employees Retirement Trust and Plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund ("Plaintiffs"), for the benefit of nominal defendant JPMorgan Chase & Co. ("JPM" or the "Company"), bring the following Verified Amended Stockholder Derivative Complaint (the "Complaint") against Defendants James Dimon, Stephen B. =, Todd A. Combs, James S. Crown, Timothy P. Flynn, Mellody Hobson, John W. Kessler, Phebe N. Novakovic, and James E. Staley. The allegations of this Complaint are based on the knowledge of Plaintiffs as to themselves and the investigation of counsel, including the review of publicly available information and documents.
+
+## INTRODUCTION
+
+1. When an otherwise reputable financial institution learns that a client is using bank facilities to further a criminal scheme, the ensuing appropriate steps are clear: the bank terminates its relationship with the client, immediately reports the incident to regulators, and informs the board of directors of the problem. But what should this Court infer when those commonsensical — and legally required — actions do not occur?
+
+2. The bank at issue in this stockholder derivative action (the "Action") is JPM, one of the world's largest financial institutions. Based on Plaintiffs' investigation, it appears that the Company did have appropriate internal controls in place to identify suspicious activity, such as massive cash withdrawals and wires by Jeffrey Epstein ("Epstein"), a known felon convicted for soliciting a minor for prostitution and clouded by allegations of rampant sexual abuse. Indeed, beginning in 2006, JPM's compliance staff repeatedly flagged the need to end the bank's ties to Epstein, sending distress calls all the way up to the Company's second most-powerful decisionmaker, Defendant James "Jes" Staley ("Staley").
+
+3. For instance, in 2011, JPM's own General Counsel, Stephen Cutler ("Cutler"), documented his unambiguous recommendation about Epstein, emailing Staley and CEO of JPM's Asset and Wealth Management business, Mary Erdoes ("Erdoes"), among others: "This is not an honorable person in any way. He should not be a client" Despite these calls to cut ties with Epstein making it to the Company's C-suite — and, some of these cries coming from the C-suite itself - Epstein remained a client until 2013, JPM did not report Epstein's suspicious activity to
+
+regulators, and there is no evidence that JPM's board of directors (the "Board") ever discussed Epstein prior to his death by apparent suicide in 2019.
+
+4. The fundamental question that this Action presents is, why? Why didn't Staley, his boss, Defendant Chief Executive Officer ("CEO") and Chairman Jamie Dimon ("Dimon"), and the JPM Board fire Epstein and his affiliates after the imperative of terminating the relationship was recognized throughout the organization? JPM has proffered one answer, although it is both implausible and unsatisfying. In recent litigation, the Company has tried to lay all of the blame on Staley for the Company's ongoing relationship with Epstein, which facilitated Epstein's payments to victims and network of enablers. In particular, JPM faults Staley for not reporting his alleged knowledge of— and personal participation in — Epstein's crimes to the Company.
+
+5. Even assuming that Staley obscured his relationship with Epstein, Staley's misconduct does not tell the whole story. JPM executives — who presumably attended Board meetings and reported to directors — plainly were aware of the Company's compliance department's urges to fire Epstein. And, the Board — comprised of intelligent people at the forefront of the business world — very likely were aware of rampant allegations of sexual misconduct levied against a purported billionaire deeply integrated into the highest reaches of the financial and political communities.
+
+6. So, again, why did none of the JPM fiduciaries take action? As detailed below, Epstein was anything but a "regular" counterparty and client. Independent of the child sex rings that made him one of the world's most notorious criminals, he had a uniquely diverse set of connections to the people who shaped the JPM of today and who still control its operations. These connections may explain why these fiduciaries proverbially "put their heads in the sand" and hoped
+
+the Company's (and their own) ties to Epstein would go unnoticed—a far more plausible story than JPM's tale making Staley the lone scapegoat.
+
+7. At bottom, the failure by the individuals at the very top of JPM to do the obvious thing their fiduciary duties required, i.e., to cut Epstein off at the very latest by his 2008 guilty plea for soliciting a minor for prostitution, likely reflects something worse than a "mere" failure of internal controls or poor oversight. Instead, it reflects, at a minimum, a bad faith disregard for their duties.
+
+\*\_\*\_\*\_\*\_\*\_\*
+
+8. Epstein was anything but a "run of the mill" JPM client. After a young Jeffrey Epstein suddenly left Bear Steams in 1980, he audaciously opened a financial advisory firm, J. Epstein & Co., premised on only representing billionaires. Somewhat inexplicably, he succeeded in not only advising, but often gaining the full power of attorney over the fortunes of some of the world's richest and most powerful people. Those (presumably legitimate) connections and the banking services needed to cater to that clientele would make him a marquee client that should get the attention of any bank CEO and board.
+
+9. Beyond the profits his advisory firm could generate, Epstein also had alleged ties to some of the darker corners of the geo-political community, including personal entanglement in some of the most notorious financial and political schemes of the 1980s and 1990s. It is almost inconceivable that a person whose entire career implicates so many widely reported scandals (such as infamous hedge fund Ponzi schemes, stealing software with national security implications, and even financing weapons and drug trade in the Iran-Contra affair) can go through any respectable Know Your Customer ("KYC") bank vetting process without being tagged from the outset as a high-risk client.
+
+10. But Epstein's reach also extended to the events and people who made JPM the institution it is today. In fact, by using his close friendship with apparel giant Leslie "Les" Wexner ("Wexner") as an entryway into the business and social elite circles of Columbus, Ohio, Epstein developed direct or one-step-removed financial or personal ties to a range of individuals who served or currently serve on the JPM Board.
+
+I. These entanglements start no later than the 1980s, when Epstein salvaged a major financing and real estate transaction in which a number of power players in the Columbus, Ohio business community participated. During that period, Wexner worked with prominent local executives, including future JPM directors James S. Crown ("Crown") and John W. Kessler ("Kessler") and the family (which founded and controlled Bank One Corporation ("Bank One"), the largest bank in Ohio), to develop an idyllic community called New Albany, Ohio, which sought to house some of the most influential names in American business.
+
+12. The Crown family had inherited via merger General Dynamics Corporation ("General Dynamics"), a weapons manufacturer with deep governmental ties, and enjoyed seats on the board of First Chicago, another prominent Midwestern bank, before it was acquired by Bank One and Crown joined the Bank One board. Kessler was a well-connected and prominent corporate lawyer in Columbus, Ohio, who advised on a wide range of deals for Wexner, the McCoys, and the Crowns alike, and enjoyed a seat on the Bank One board.
+
+13. Despite being backed by a marquee lineup of Columbus citizens, the New Albany project struggled initially. Its early development was exceedingly expensive and complex, and was mishandled by its original financial leadership. That changed after Epstein came along. Epstein was given a partnership interest in the New Albany project for a nominal investment.
+
+Epstein promptly re-organized and restructured the New Albany development project so it could take hold, be completed, and ultimately flourish.
+
+14. Until 2000, Dimon had established his Wall Street reputation by serving as secondin-command in helping Sanford "Sandy" Weill ("Weill") transform his purchase of several financial institutions with links to both Epstein and British financier Robert Maxwell (whose daughter Ghislaine remains in jail for her critical role in Epstein's sex trafficking ring) into the current-day global banking behemoth Citigroup. After Dimon and Weill split up in 1998, Dimon re-emerged as Bank One's CEO, replacing a member of the family. Crown and Kessler both sat on the Bank One board and, as detailed below, had glowing things to say about Dimon. Thereafter, Dimon ingratiated himself in and publicly praised the Columbus business community, to which Epstein was described as "ubiquitous." While Dimon denies ever meeting Epstein, his professed ignorance of the man's existence strains credibility.
+
+IS. After JPM's 2003 acquisition of Bank One, several former Bank One directors and officers joined the highest ranks of the Company, including Dimon, Crown, Kessler, Stephen B. ("="), and Linda B. Bammann ("Bammann"). It also appears that even before the merger, JPM knew that Epstein was not a "typical" client, be it his line to banking services for billionaire clients or more controversial issues. Staley, the head of JPM's private bank at the time, claims that he was told in 2000 to "get to know" his new (and presumably important) client.
+
+16. Put simply, Defendants may not have known that Epstein catered to the worst proclivities of some of the world's most powerful people. But it appears that numerous people at the apex of Bank One's, and later JPM's, decision-making structure not only knew of Epstein, but also either had direct dealings with him or understood that they were engaged in significant business with no more than a single degree of separation from Epstein. Epstein got attention from
+
+the outset, and any functioning KYC onboarding process would make him a high-risk client garnering extra monitoring and attention from the outset.
+
+17. Whether or not he was so designated from the outset, it did not take long for JPM employees to begin openly questioning the Company's ongoing relationship with Epstein. A September 2006 New York Times article about Epstein's arrest for soliciting a minor for prostitution triggered emails among JPM executives, including Erdoes, where she observed (sarcastically) that Epstein was "a lovely guy to work with."
+
+18. By the time of Epstein's 2008 guilty plea to the solicitation charge, JPM labeled Epstein a "high-risk" client, and many employees expressed the obvious need to terminate the relationship. In fact, a mid-July 2008 internal risk function memorandum documented that "Catherine [Keating, the CEO of the Company's Private Bank] will go back to Jes [Staley, then the CEO ofJPM's Asset Management Division] to tell him we are uncomfortable with Epstein..."
+
+19. Even more striking, in August 2008, a JPM employee wrote that she "would count Epstein's assets as a probable outflow for '08 (\$120mm or so?) as I can't imagine it will stay (pending [Jamie) Dimon review)." Whether Staley blocked the expected "Dimon review" or someone with authority (such as Dimon or a Board member) provided informal and tacit support to Epstein and thus obviated the formal "Dimon review" process, Epstein remained with JPM.
+
+20. Despite Epstein's 2008 guilty plea and ongoing sex crime allegations, neither JPM nor Staley ended their relationship with Epstein. Between 2008 and 2013, Staley and Epstein exchanged 1,200 emails (including pictures of young girls in seductive poses). Inexplicably, the bank's risk reviews of Epstein's accounts uncovered precisely zero of his grossly improper communications with Staley.
+
+21. By mid-2010, a risk management division employee referred to "new allegations of an investigation related to child trafficking," and asked whether JPM was "still comfortable with this client who is now a registered sex offender." Other JPM compliance employees decided that Epstein "should go."
+
+22. Far from breaking off relations with the man who served as power of attorney for Wexner (a known JPM billionaire client) and unknown other billionaires and who played a role in bringing the New Albany, Ohio business elite to the heights of Wall Street and global finance, in December 2010, JPM granted Epstein a new \$50 million line of credit.
+
+23. As Epstein's notoriety as an international criminal became more obvious, internal efforts to distance the Company from the criminal client only grew louder. Yet no amount of risk management could overcome the failure (or refusal) of senior management and the Board to intervene to protect the Company.
+
+24. An internal March 2011 report explained that a company named "MC2 Model Management and Jeffrey Epstein engaged in racketeering that involved luring in minor children for sexual play for money," and that MC2 Model Management's owner was a "frequent passenger on Epstein's private jet and often visited Epstein in jail."
+
+25. On July 20, 2011, JPM's General Counsel Cutler emailed Staley and Erdoes, among others, writing of Epstein: "This is not an honorable person in any way. He should not be a client." The next day, Cutler emailed Erdoes again, describing Epstein as: "Not a person we should do business with, period." Nevertheless, Epstein's accounts with the bank remained open and functional.
+
+26. JPM continued doing business with Epstein personally until 2013, and potentially continued to engage with Epstein related entities until his death in jail in 2019. In fact, the
+
+Company actively concealed Epstein's crimes by failing to file any legally required Suspicious Activity Reports ("SARs"), which are mandated for large cash withdrawals and other suspicious transactions.
+
+27. The Company's refusal to timely cut off its relationship with Epstein has harmed the Bank already and is continuing to do so. JPM recently agreed to pay \$290 million to settle a class action lawsuit brought by Epstein's victims. JPM faces an ongoing lawsuit by the government of the U.S. Virgin Islands in connection with harm it suffered due to the Company financing Epstein's use of a home base in the U.S. Virgin Islands until his arrest in 2019.
+
+28. In sum, the story of Epstein using Company bank accounts and resources to support his child sex trafficking ring was not a single client slipping through the cracks in the system. Company fiduciaries knew about Epstein and his admitted and alleged crimes, but Epstein was not "just" a client. He was a business partner and colleague to various members of JPM management and the Board. The bank's delay and refusal to address (and end) its unacceptable relationship with Epstein thus likely reflects a "head in the sand" attitude, with JPM officers and directors hoping the world would not discovery the Company's facilitation of Epstein's crimes. Unfortunately for them, the Company's ties to Epstein have come to light and caused significant damage to JPM. Demand is excused, and the defendant fiduciaries should be accountable.
+
+### PARTIES AND RELEVANT NON-PARTIES
+
+## I. PARTIES
+
+## A. Plaintiffs
+
+29. Plaintiff City of Miami General Employees' & Sanitation Employees' Retirement Trust is a pension fund providing retirement benefits to active and retired employees of the City of Miami, Florida.
+
+30. City of Miami General Employees' & Sanitation Employees' Retirement Trust owns 27,950 shares of JPM common M, has continuously held JPM common since December 2016, and is currently a stockholder of the Company. City of Miami General Employees' & Sanitation Employees' Retirement Trust brings this Action derivatively on behalf of JPM and its stockholders to redress injuries that the Company suffered and will suffer as a direct result of Defendants' breaches of fiduciary duty. City of Miami General Employees' & Sanitation Employees' Retirement Trust intends to retain JPM shares throughout the duration of this litigation.
+
+31. Plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund is a stockholder of JPM, and has held JPM since 2010.
+
+# B. Nominal Defendant
+
+32. Nominal defendant JP Chase & Co. (as previously defined, "JPM" or the "Company") is a Delaware corporation headquartered in New York, New York, that operates as a global investment bank, providing financial services in the United States and across the globe. JPM's principal bank subsidiary is JP Chase Bank, N.A. The Company is publicly traded on the New York Exchange under the ticker "JPM."
+
+### C. Director Defendants
+
+33. Defendant James S. Crown (as previously defined, "Crown") was a director of JPM from 2004 until June 2023. He served as a member of both the Public Responsibility Committee and the Risk Committee of the Board. Prior to its merger with JPM, Crown served as a director of Bank One from 1991 to 2004. Crown was one of the key people who selected Dimon as the CEO of Bank One in 2000 and advocated for his ascent at JPM. From 1987 to June 2023, Crown served as a director for General Dynamics, an aerospace defense giant inherited by the Crown family following its merger with MSC in 1959. He joined General Dynamics as lead director in 2010. Crown was a resident of Chicago, Illinois.
+
+34. Defendant John W. Kessler (as previously defined, "Kessler") was a director of JPM from 2004 to 2007. Prior to joining JPM's board, Kessler served as a director of Bank One from 1995 to 2004. From 1998 to present, he has been the chairman of the New Albany Company. Kessler also served on the board of Wexner's company, Abercrombie & Fitch. Kessler is an individual and is believed to be a resident of New Albany, Ohio.
+
+35. Defendant Stephen B. (as previously defined, `=") has been a director of JPM since 2004. Prior to its merger with JPM, served as a director of Bank One while Dimon was Bank One's CEO. From 2011 until his retirement in 2020, was the Chairman and COO of NBCUniversal, LLC and NBCUniversal Media, LLC. made headlines at NBCUniversal during the Harvey Weinstein scandal after Ronan Farrow alleged that was warned in 2015 about a culture of sexual harassment at NBC's news division. is an individual and is believed to be a resident of Dillon, Montana.
+
+36. Defendant Phebe N. Novakovic ("Novakovic") has been a director of JPM since 2020. From 2013 to present, Novakovic has served as the Chairman and CEO of General Dynamics, the aerospace defense company affiliated with the Crown family. As previously noted,
+
+Crown had been a member of General Dynamics board since 1987. Novakovic has served in a variety of leadership roles at General Dynamics since her start in 2002. Before joining General Dynamics, Novakovic worked for the United States Department of Defense from 1997 to 2001 and prior to that she served as an officer for the Central Intelligence Agency. Novakovic is an individual and is believed to be a resident of Annapolis, Maryland.
+
+37. Defendant Timothy P. Flynn ("Flynn") has been a director of JPM since 2012. He is also a member of the Audit Committee of the Board. In his professional career, Flynn held various leadership roles at KPMG LLC in the US and finished his career as the Chairman of KPMG International in 2011. Flynn has been a director of United Health Group since 2017 and of Wal-Mart Stores, Inc since 2012. He was previously a director of the Alcoa Corporation and Chubb Corporation, and a member of the World Economic Forum's International Business Council. Flynn is an individual and is believed to be a resident of Marana, Arizona.
+
+38. Defendant Todd A. Combs ("Combs") has been a director of JPM since 2016. Combs was a member of the Risk Policy Committee of the Board from 2017 to 2019. Combs is an individual and is believed to be a resident of Omaha, Nebraska.
+
+39. Defendant Mellody Hobson ("Hobson") has been a director of JPM since 2018. She serves a member of both the Public Responsibility Committee and the Risk Committee of the Board. Hobson was a member of the Audit Committee of the Board in 2019. Hobson is presently the Co-CEO of Ariel Investments, LLC ("Ariel Investments") where she has served as President and director since 2000. Ariel Investments was founded by John Rogers, a former Bank One director who served with Defendant Crown, among others, and was on the Bank One board at the same time Dimon served as Bank One's CEO and one of its directors. Hobson is an individual and is believed to be a resident of Chicago, Illinois.
+
+40. As used herein, "Director Defendants" refers to Dimon, Crown, Kessler, Novakovic, Flynn, Combs, and Hobson.
+
+## D. Officer Defendants
+
+41. Defendant James "Jamie" Dimon (as previously defined, "Dimon") has been a director of JPM since 2004. Dimon has been JPM's CEO since 2005 and Chairman of the Board since 2006. Until 1998, Dimon served as the President of Citigroup, under the leadership of his long-term mentor, Weill. Amidst growing tensions between the two, Dimon was fired by Weill that year. In 2000, Dimon was selected to become the new CEO of Bank One. In 2003, JPM purchased Bank One, launching Dimon into his role as JPM's CEO, which he assumed in 2005. Dimon is an individual and is believed to be a resident of New York, New York.
+
+42. Defendant James E. Staley (as previously defined, "Staley") was the CEO of JPM's Investment Bank from September 2009 through January 2013. Previously, Staley was the CEO of JPM's Asset Management division from 2001 to 2009 and was the head of JPM's Private Banking division from 1999 to 2001. Staley is an individual and is believed to be a resident of Manhattan, New York.
+
+43. As used herein, "Officer Defendants" refers to Dimon and Staley.
+
+44. As used herein, "Individual Defendants" refers to the Directors Defendants and the Officer Defendants.
+
+# II. RELEVANT NON-PARTIES
+
+45. Mary C. Erdoes (as previously defined, "Erdoes") joined JPM in 1996 as head of fixed income for high-net-worth accounts. She became CEO of JPM's Private Bank in 2005. In September 2009, Erdoes obtained her current role as CEO of JPM's Asset & Wealth Management division. Besides Dimon, Erdoes is the longest serving member of the JPM operating committee, which is comprised of the Company's most senior executives.
+
+#### JURISDICTION AND VENUE
+
+46. The Court has jurisdiction over this action pursuant to 28 U.S.C. § 1332. The Court has supplemental jurisdiction over the state law claims asserted herein pursuant 28 U.S.C. § 1367(a). This action is not a collusive one to confer jurisdiction on a court of the United States which it would not otherwise have.
+
+47. Venue is proper in this Court because JPM has its principal place of business in this District, Plaintiffs' claims arose in this District, and JPM has suffered and will continue to suffer harm in this District.
+
+48. Pursuant to Local Civil Rule 1.6(a), the undersigned believe that this action is related to Jane Doe / Doe v. JP Chase Bank, N.A., 22-cv-10019 (JSR) (the "Jane Doe Action") and Government of the United States Virgin Islands v. JP Chase Bank, N.A., 22 cv-10904 (CSR) (the "USV/ Action"), which are currently pending before this Court. This Action and those actions arise from a common nucleus of operative fact involving JPM's participation, directly or indirectly, in Epstein's sex-trafficking venture by facilitating payments to women and girls, channeling funds to Epstein to fund the operation, and concealing Epstein's criminal conduct by violating federal banking regulations.
+
+# SUBSTANTIVE ALLEGATIONS
+
+## I. COMPLIANCE WITH BANKING LAWS AND REGULATIONS IS MISSION-CRITICAL TO JPM'S BUSINESS
+
+49. As a global financial institution, compliance with banking laws and regulations is mission-critical to JPM's business. The Company acknowledges that it "is subject to extensive and comprehensive regulation under U.S. federal and state laws, as well as the applicable laws of the jurisdictions outside the U.S. in which the Firm does business."'
+
+50. JPM's national bank subsidiary, JP Chase Bank, N.A., "is supervised and regulated by the Office of the Comptroller of the Currency (`OCC') and, with respect to certain matters, by the Federal Deposit Insurance Corporation (the `FDIC')."2
+
+51. Failure to comply with this "extensive and comprehensive regulation" could have severe consequences on JPM's business. Indeed, the first "Risk Factor" that the Company identifies in its annual report is "Regulatory,"3 and JPM proceeds to warn that "[r]esolving regulatory investigations can subject JP Chase to significant penalties and collateral consequences," including "greater exposure to litigation" and damage to JP Chase's reputation."4 Accordingly, JPM — and each of the Defendants — knew that regulatory compliance (including with the laws and rules discussed herein) was "mission-critical" to the Company.
+
+52. Because financial institutions like JPM are susceptible to serving as conduits for significant financial crimes, the federal government has established a series of anti-money laundering ("AML") laws and regulations. The primary federal laws governing banks with respect
+
+JPMorgan Chase & Co., Annual Report (Form 10-K), at t(FS. 21, 2023). Since at least 2006, the Company has made similar disclosures. See, e.g., JP Chase & Co., Annual Report (Form 10-K), at 6 (Mar. 9, 2006) ("JPMorgan Chase operates within a highly regulated industry and its business and results are significantly affected by the regulations to which it is subject.").
+
+<sup>2</sup> JPMorgan Chase & Co., Annual Report (Form 10-K), at 4 (Feb. 21, 2023).
+
+<sup>3</sup>Id. at 9.
+
+<sup>4</sup> Id. at 11. Since at least 2006, the Company has made similar disclosures. See, e.g., JP Chase & Co., Annual Report (Form 10-K), at 6 (Mar. 9, 2006) ("JPMorgan Chase faces significant legal risks, both from regulatory investigations and proceedings and from private actions brought against the firm. . . . These or other future actions brought against the Firm may result in judgments, settlements, fines, penalties or other results adverse to the Firm which could materially adversely affect the Firm's business, financial condition or results of operation, or cause it serious reputational harm.").
+
+to AML are the Federal Bank Secrecy Act ("BSA") and certain provisions of the USA Patriot Act (the "Patriot Act").5
+
+53. The BSA and Patriot Act require financial institutions to implement adequate riskbased AML policies and systems to detect and prevent money laundering and other uses of a bank's services and resources to facilitate criminal activities. Such requirements include maintaining a due diligence program, filing SARs after detecting suspicious behavior, filing currency transaction reports ("CTRs") for currency transactions or series of currency transactions that exceed \$10,000 in a 24-hour period, preventing structuring or assistance with structuring of transactions undertaken for the purpose of evading federal reporting requirements, and maintaining systems to prevent money laundering.
+
+54. The Federal Financial Institutions Examination Council ("FFIEC") — a formal U.S. government interagency body of banking regulators that is empowered to prescribe uniform principles, standards, and report forms to promote uniformity in the supervision of financial institutions — has published a Bank Secrecy Act / Anti-Money Laundering Examination Manual (the "FFEIC Manual") to provide further guidance to financial institutions on BSA / AML compliance.6 FFIEC is comprised of the Board of Governors of the Federal Reserve System, the FDIC, the National Credit Union Administration, the OCC, and the Consumer Financial Protection Bureau.
+
+55. The FFEIC Manual makes clear that ultimate responsibility for regulatory compliance lies with the financial institution's board of directors: "The board of directors, acting
+
+<sup>5</sup> United Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, Pub. L. No. 107-56, 115 Stat. 272.
+
+<sup>6</sup> FFIEC regularly updates the FFEIC Manual. Given the relevant period for this Complaint, cites herein are to the 2006 edition of the FFEIC Manual.
+
+through senior management, is ultimately responsible for ensuring that the bank maintains an effective BSA/AML internal control structure, including suspicious activity monitoring and reporting."' Such controls should include:8
+
+- "Identify[ing] banking operations . . . more vulnerable to abuse by money launderers and criminals; provid[ing] for periodic updates to the bank's risk profile; and provid[ing] for a BSA / AML compliance program to manage risks."
+- "Informfingl the board of directors, or a committee thereof, and senior management, of compliance initiatives, identified compliance deficiencies, and corrective action taken, and notify directors and senior management of [SARs] filed."
+- "Implementfing/ risk-based customer due diligence (CDD) policies, procedures, and processes."
+- "IdentiMingl reportable transactions and accurately file all required reports including SARs, [CTRs], and CTR exceptions."
+- "Provid[ing] sufficient controls and monitoring systems for timely detection and reporting of suspicious activity."
+
+56. The FFEIC Manual explains that effective CDD policies are "critical" because they are needed for. (a) "[d]etecting and reporting unusual or suspicious transactions that potentially expose the bank to financial loss, increased expenses, or reputational risk"; (b) "[a]voiding criminal exposure from persons who use or attempt to use the bank's products and services for illicit purposes"; and (c) "[a]dhering to safe and sound banking practices."9
+
+57. With respect to "high-risk customers," the FFEIC Manual instructs that "[e]nhanced due diligence . . . is especially critical in understanding their anticipated transactions
+
+<sup>7</sup> Bank Secrecy Act / Anti-Money Laundering Examination Manual, Federal Financial Institutions Examination Council, at 29 (2006), available at https://www.ffiec.gov/pdfibsa\_aml\_examination\_manual2006.pdf.
+
+<sup>8</sup> Id. at 29-30.
+
+<sup>9</sup> Id. at 56.
+
+and implementing a suspicious activity monitoring system that reduces the bank's reputation, complaint, and transaction risks."10 Moreover, "due diligence is an ongoing process" and risk profiles should be adjusted as necessary."
+
+58. Closely related to a bank's CDD policies is its suspicious activity reporting, which the FFEIC Manual calls "the cornerstone of the BSA reporting system."' Banks arc required to file a SAR with respect to, among other things:13
+
+- "Criminal violations aggregating \$5,000 or more when a suspect can be identified."
+- "Criminal violations aggregating \$25,000 or more regardless of a potential suspect."
+- "Transactions conducted or attempted by, at, or through the bank . . . aggregating \$5,000 or more, if the bank .. . knows, suspects, or has reason to suspect that the transaction": (a) "Imlay involve potential money laundering or other illegal activity; (b) "Ns designed to evade the BSA or its implementing regulations"; or
+  - (c) "Alas no business or apparent lawful purpose or is not the type of transaction that the particular customer would normally be expected to engage in, and the bank knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction.
+
+59. The FFEIC Manual continues: "Appropriate policies, procedures, and processes should be in place to monitor and identify unusual activity."10 When a bank detects suspicious activity, it must file a SAR within 30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network." Moreover, where there is continuing suspicious activity, a bank should file a SAR at least every 90 clays."
+
+<sup>10</sup>Id. at 57.
+
+IIId. at 58.
+
+<sup>12</sup> Id. at 60.
+
+<sup>&</sup>quot; Id. at 60-61.
+
+<sup>14</sup> 1d. at 61.
+
+<sup>15</sup> Id. at 66, 68.
+
+<sup>16</sup> Id. at 69.
+
+60. Banks are required to notify their boards of directors when SARs have been filed," and the FFEIC Manual advises that "management should provide sufficient information on its SAR filings to the board of directors or an appropriate committee in order to fulfill its fiduciary duties."I8 Under the laws of Delaware — JPM's state of incorporation — the Board's fiduciary duties require them to implement adequate oversight systems to ensure compliance with laws and regulations, including the BSA and the Patriot Act.
+
+### IL EPSTEIN'S PRE-JPM PROFESSIONAL BACKGROUND MADE HIM A "HIGH RISK-HIGH REWARD" CLIENT FROM THE OUTSET
+
+61. Historical context is necessary to appreciate why and how Epstein could thrive within JPM even though a person without links to the bank's power centers would surely have been reported to authorities and terminated as a client when his status as a child sex trafficker became known within the Company.
+
+62. Epstein's history and notoriety at the time of his earliest interactions with JPM supports the inference that, from the outset, he would have been recognized as a high-risk, but high-reward, client, and would likely have been reported to the highest levels within the Company. What already was known around the time Epstein was onboarded at JPM in 1998 — not to mention what came to light in 2002 to 2003 — begs the question of whether plentiful red flags were intentionally ignored by those in positions of power to retain Epstein as a client, overriding the many concerns that his history should have raised.
+
+63. Based solely on the sheer volume of money for an exceedingly high-profile clientele that Epstein purported to handle, it is probable that his seeking to open an account would have been brought to the attention of any bank CEO. Even when the JPM onboarding process for
+
+<sup>17</sup> Id. at 67.
+
+<sup>18</sup> Id. at 68.
+
+Epstein was taking place around 1998, there were already an array of reasons that his desire to bank with JPM would have garnered attention from the highest levels of the Company, and should have triggered KYC measures.
+
+64. Among these red flags were a trail of financial irregularities and crimes left in Epstein's wake among those he was known to be close to, including an SEC investigation into insider trading during his time at Bear Steams, his proximity to the Tower Financial Ponzi scheme, and his incredibly close ties to Robert Maxwell, whose theft of over \$1.2 billion of his clients' money had recently come to light. Epstein's history even at this time also included early red flags of his horrific sexual abuses, still being unearthed and litigated to this day.
+
+# A. The Founding and Expansive Reach of J Epstein & Co
+
+65. In the summer of 1974, Epstein found himself within the halls of the prestigious Dalton School on Manhattan's Upper East Side, teaching physics and calculus, despite the fact that he was 21 years old and had no college degree. Epstein's foray into education, however, proved short-lived. In 1976, he traded his classroom for the financial sphere, securing a position at Bear Steams — an institution that would later be subsumed by JPM.
+
+66. Working under the direct tutelage of Wall Street legends Alan "Ace" Greenberg and James "Jimmy" Cayne, Epstein rapidly ascended the Bear Stems ranks, attaining the title of senior partner by 1980. However, shortly thereafter, the Securities and Exchange Commission ("SEC") initiated a formal investigation into Bear Steams about insider trading around a tender offer placed on March 11, 1981, by the Seagram Company Ltd. for St. Joe Minerals Corp. Epstein left Bear Stearns the next day, March 12, 1982. This investigation included at least one personal interview with Epstein by the SEC on April I, 1981, regarding potential charges, and it has been reported that Epstein left behind a string of financial irregularities at Beam Steams, which perhaps explains his swift exit from the company.
+
+67. In fact, according to his SEC interview and a contemporaneous Bear Stearns memorandum from the Executive Committee, Epstein left the company because he had illicitly lent money to clients. The transcript of this interview and its exhibits (including the memorandum from the Executive Committee) are publicly available. After being fined and suspended by the Executive Committee, Epstein resigned.
+
+68. Epstein opened his own financial advisory firm, named J Epstein & Co., in 1982. The company did not employ any analysts or portfolio managers, operating instead with approximately twenty accountants. Despite lacking any marketing efforts, grand opening announcements, or even simple promotional flyers, J Epstein & Co. mysteriously thrived a mere year after its establishment, boasting a client base consisting of a large number of ultra-high net worth individuals. The firm purported to cater exclusively to clients with a net worth of \$1 billion or more — a striking anomaly in the financial industry at the time when billionaires were considerably rarer.19 In fact, a 2002 article in New York Magazine reported that Epstein was known to scoff at offers to manage accounts of less than \$1 billion, flatly — and often rudely — turning down requests to manage accounts of \$500 million or \$700 million as "too small."2°
+
+69. While some have questioned his veracity, Epstein consistently claimed that the world's wealthiest and most influential people flocked to give Epstein control over their finances.
+
+70. Importantly, according to those acquainted with him or under his employment, Epstein's business model hinged on maintaining absolute control over his clients' assets. He went so far as to assume power of attorney over his clients' assets, providing him with total control over these immense pools of wealth, and unfettered authority over the finances of some of the world's
+
+<sup>19</sup> Landon Jr., Jeffrey Epstein: International Moneyman of Mystery, N.Y. MAG. (Oct. 28, 2002), https://nymag.cominymetro/news/people/n\_7912/.
+
+<sup>&</sup>quot; Id.
+
+wealthiest individuals. <sup>21</sup> At the time, Epstein's most significant confirmed client was Wexner, the billionaire behind Limited Brands and Victoria's Secret — and a director of Columbus-based Bank One. As discussed below, Epstein's close connection with Wexner paved the way for his entanglement with the Bank One and later JPM boards.
+
+### B. Epstein's Known Ties to the Maxwells Should Have Made Him a "High Risk" Client From the Time of His Onboarding at JPM
+
+71. In the early 1980s, Epstein spent his days traveling between England and the United States where he integrated into social circles comprised of socialites, arms-dealers, spies, billionaires, politicians, gangsters, and various other influential figures. While in England, Epstein first encountered British media baron Robert Maxwell, the father of Ghislaine Maxwell (with whom Epstein would later partner in running his sex trafficking rings).
+
+72. Throughout his life, Robert Maxwell was renowned as a media proprietor, a member of the British Parliament, a suspected spy, and, later on, a notorious fraudster. Most importantly, he was eye-poppingly rich and offered Epstein the connections and money that helped to turn J Epstein & Co into a massive financial advisory business. As explained in more detail below, some of these connections included General Dynamics and the Crown Family, a member of which sat on the Bank One board and currently sits on the JPM Board, i.e., Defendant Crown.
+
+73. Prior to his mysterious death on his yacht in the middle of the Atlantic Ocean in 1991, Robert Maxwell faced allegations of espionage for the Israeli Intelligence Directorate ("HD"). Following his death, these accusations were corroborated by former HD employees and an unnamed U.S. intelligence official 22
+
+<sup>21</sup>Id.
+
+<sup>22</sup> Whitney M, Former Israeli Intel Official Claims Jeffrey Epstein, Ghislaine Maxwell Worked for Israel, MINTPRESS NEWS (Oct. 2, 2019), https://www.mintpressnews.com/ari-ben-menashejeffrey-epstein-ghislaine-maxwell-israel-intelligence/262162/.
+
+74. Whether or not he had links to intelligence agencies, Robert Maxwell served as a mentor to Epstein, even hoping that Epstein would become his son-in-law. As Ari Ben Menashe, the former IID employee who claimed to be Maxwell's "handler," put it, "Robert Maxwell saw in Jeffrey Epstein a potential husband for his daughter and a potential business partner for himself."23 It appears that Ghislaine Maxwell's father introduced her to Epstein in the 19805.24
+
+75. Epstein presented himself to Ghislaine Maxwell as a financial expert who could help her family finance its business. During that time period, Robert Maxwell allegedly needed a \$50 million bridge loan, which Epstein secured.25
+
+76. According to reporting by, among others, Seymour Hersh, under Robert Maxwell's guidance, both Ghislaine Maxwell and Epstein participated in a clandestine operation involving arms dealing, blackmail, and financial fraud, which ultimately played a role in the Iran-Contra scandal. But that connection also provided the basis for a more strengthened Epstein-Ghislaine Maxwell link.
+
+77. Robert Maxwell's involvement with Israeli intelligence became evident following his meeting with Epstein in London in the 1980s. Maxwell was allegedly involved in the PROMIS scandal, also known as the "Inslaw Affair.s26 PROMIS, short for "Prosecutors Management Information System," was a software developed by U.S.-based Inslaw Inc. and designed to help
+
+<sup>23</sup> Michael McKinley & Barbara Shearer, Ghislaine Maxwell: Privilege, Power, Perversion, INKSHARES, https://www.inkshares.com/booksIghislaine-maxwell-privilege-powerperversion/book\_segments/meeting-jeffrey.
+
+<sup>24</sup> Id.
+
+<sup>25</sup> Id.
+
+<sup>26</sup> Emma North-Best, Sir Robert Maxwell's FBI File is Getting More Classified By the Minute, MUDROCK (June 28, 2017), https://www.muckrock.com/news/archives/2017/jim/28/sir-robertmaxwells-fbi-PROMIS/.
+
+federal and state prosecutors track and flag potential money laundering operations and suspicious wire transfers.27
+
+78. According to investigative journalist covering the Inslaw Affair, Earl Brian, an associate of President Ronald Reagan, and his Attorney General Edwin Meese ("Meese"), sought to acquire access to this software. Meese and members of the Department of Justice covertly obtained the PROMIS software intending to use it to help U.S. intelligence organizations indirectly facilitate the very crimes that the program was supposed to prevent.
+
+79. The software also landed in the hands of Israeli agents, who installed a backdoor into the program and attempted to sell it to U.S. military-industrial companies, including General Dynamics (affiliated with the Crown family that later enjoyed seats on the Bank One and JPM boards of directors). The alleged intermediary for this operation was Robert Maxwell.
+
+80. Given the high volume of publicity surrounding Ghislaine Maxwell and Epstein's relationship in the 1990s, Epstein's ongoing dealings with the Maxwell family would inevitably have come up in any adequate bank onboarding or KYC due diligence process.
+
+### C. Epstein's Role in the Tower Financial Ponzi Scheme and Affiliation With Founder Steve Hoffenberg Should Have Raised Major Red Flags During his JPM Onboarding
+
+81. In 1993, Steven Hoffenberg ("Hoffenberg"), one of Epstein's early mentors, was convicted for perpetrating one of the largest Ponzi schemes prior to Bernie Madoff.
+
+82. Tower Financial Corporation ("Towers") came into existence in the early 1970s as a debt collection agency stationed in Manhattan, New York. Hoffenberg was the driving force behind its creation, taking on the roles of Chairman, CEO, and President. In 1987, shortly after
+
+<sup>27</sup> Richard L. Fricker, The INSLAW Octopus, WIRED (JAN. I, 1993, 12:00 PM), https://www.wired.com/ 1 993/01/inslaw/.
+
+Epstein's departure from Bear Stearns, Hoffenberg was introduced to Epstein by Sir Douglass Leese, who had ties to Robert Maxwell.
+
+83. Regarding Epstein, Leese told Hoffenberg: "He's great at selling securities. And he has no moral compass."28 Hoffenberg thereafter welcomed Epstein into the fold as a consultant, providing him with a monthly salary of \$25,000 (roughly \$67,000 in today's dollars). When prompted about his association with Epstein years later, Hoffenberg stated, "He was my best friend for years. My closest friend for years.""
+
+84. In February 1993, the SEC lodged charges against Towers, Hoffenberg, and the remaining executive committee for perpetrating a \$460 million Ponzi scheme that defrauded nearly 200,000 Americans. Hoffenberg pleaded guilty to fraud, obstruction of justice, and tax evasion in 1995, and was sentenced to a 20-year prison term. Hoffenberg's co-conspirators received sentences ranging from seven to nine years.
+
+85. While Epstein escaped charges, numerous press articles and court documents suggest Epstein was initially implicated in the scheme, with some witnesses even naming him as the true architect. Yet, his name mysteriously disappeared from the court records.30 In any event,
+
+<sup>28</sup> Marc Fisher & Jonathan O'Connell, Jeffery Epstein: The Trail of Ruined Lives, Misery and Bankruptcy Arch-Swindler and Paedophile Left in His Wake, INDEPENDENT (Aug. II, 2019, 2:23 PM), https://www.independent.co.uk/news/world/americas/jeffrey-epstein-death-sex-traffickingminors-victims-justice-us-courts-fbi-investigation-a905 1911 .html.
+
+<sup>29</sup> Brian Pascus & Mola Lenghi, Jeffrey Epstein Worked at Financial Firm That Engaged in Massive Portz' Scheme in 1980s and 1990s, CBS (August 13, 2019 9:12 AM), https://www.cbsnews.com/news/jeffrey-epstein-worked-at-towers-financial-with-stephenhoffenberg-who-committed-ponzi-scheme-crimes/.
+
+<sup>30</sup> Marc Fisher & Jonathan O'Connell, Final Evasion: For 30 Years, Prosecutors and Victims Tried to Hold Jeffrey Epstein to Account. At Every Turn, He Slipped Away., WASH. POST (Aug. 10, 2019, 8:53 PM), https://archive.is/20200705194823/https://wvvw.washingtonpost.com/politicsffinal-evasion-for-30-years-prosecutors-and-victims-tried-to-hold-jeffrey-epstein-to-account-at-evely-turn-heslipped-away/2019/08/10/30bc947a-bb8a- I le9-a091-6a96e67d9cce\_story.html.
+
+Epstein's role as a consultant to Towers should have been red flags to a bank with proper AML systems in place and conducting adequate KYC due diligence.
+
+86. Following Epstein's arrest and subsequent incarceration in 2019, Hoffenberg, having served 18 years in prison, alleged that Epstein had in fact been the true mastermind behind the entire scheme. When questioned about his silence on Epstein's involvement, Hoffenberg claimed that Epstein had significant sway within the United States Department of Justice, further emphasizing, "You cannot grasp the magnitude of (Epstein's] controlling effect.i31 Given the sheer scale of the scheme and the extensive media coverage it attracted, it is hard to believe that major players in the financial world who worked with Epstein remained ignorant of Epstein's identity by 1995.
+
+## III. EPSTEIN'S "UBIQUITOUS" BUSINESS TIES TO THE COLUMBUS, OHIO BUSINESS ELITE THAT CREATED AND COMPRISE JPM'S CURRENT BOARD AND LEADERSHIP MAY EXPLAIN HIS SPECIAL TREATMENT AT JPM
+
+## A. Epstein Salvages and Successfully Turns Around the "New Albany" Project Created by Wexner and Kessler
+
+87. Sometime in the early 1980s, Epstein was introduced to Wexner, the billionaire behind Limited Brands and Victoria's Secret. Wexner was one of Epstein's earliest confidants and wealthiest clients, and close associates of Wexner found it perplexing that he would so quickly entrust his fortune to a relative newcomer like Epstein. However, Epstein soon demonstrated his worth, providing timely assistance to Wexner's business venture in New Albany, Ohio.
+
+88. The New Albany project was the redevelopment of thousands of acres of farmland outside of Columbus, Ohio into a town modeled after an 18th-century Georgian village. The
+
+<sup>31</sup> Gina Tron, Jeffrey Epstein Allegedly Took Part In Ponzi Scheme Before Creating 'Molestation Pyramid Scheme,' OXYGEN (June 3, 2020, 6:30 PM), https://www.oxygen.com/true-crimebunIsteven-hoffenberg-says-jeffrey-epstein-helped-him-with-ponzi-scheme.
+
+development includes multi-million dollar homes built around a Jack Nicklaus-designed golf course. Wexner and his business partner Kessler invested significant capital into the project.
+
+89. By 1988, Wexner and Kessler's ambitious real estate project had become a financial debacle. To salvage the venture, Wexner enlisted Epstein's help. A Columbus-based investigative journalist has stated that "Before Epstein came along in 1988, the financial preparations and groundwork for the New Albany development were a total mess" and that "Epstein cleaned everything up."32
+
+90. The New Albany venture marked the first interaction between Kessler and Epstein, establishing a link to Epstein's future relationship with JPM. Kessler was a future supporter of Dimon who helped him reach the highest echelons of Bank One and JPM, placing Epstein at just one degree of separation from Dimon (at most).
+
+91. Kessler was a co-founder of New Albany and was a director on the Bank One board during its merger with JPM and stayed on as a director of JPM. He was also on the search committee that appointed Dimon as CEO of Bank One in 2000. He has described Dimon as the "best banker in the country" and stated that Dimon loves Columbus and that "he'd move everybody" at JPM to Columbus if he could.33 Kessler, of course, knew Epstein and owed the success of the New Albany project to Epstein.
+
+92. Additionally, John G. =, the father of John B. =, was an early buyer of real estate in the New Albany development. John G. had appointed Kessler to the Bank One board and they had a close relationship, with Kessler calling the senior John G. his
+
+<sup>32</sup> Landon Jr., Jeffrey Epstein: International Moneyman of Mystery, N.Y. MAG (Oct. 28, 2002), nymag.com/nymetro/news/peoplein\_7912.
+
+<sup>33</sup> CEO Jack Kessler: Local Visionary: It's How You Treat People, COLUMBUS DISPATCH (Aug. 24, 2014, 12:01 AM), https://www.dispatch.comistoryibusiness/2014/08/24/ceo-jack-kesslerlocal-visionary/23336557007/.
+
+mentor.34 John G. =, as a former executive of Bank One, close friend of Kessler, and early investor in New Albany, on information and belief interacted with Epstein.
+
+### B. Epstein's Success Ingratiated Him to Bank One, the Columbus Elite, and l uture Decision Makers at JPM
+
+93. Epstein's connections to Bank One, the Columbus elite, and JPM goes even further. As a gesture of gratitude for saving the New Albany project, Wexner and Kessler welcomed Epstein as a general partner in New Albany Co.'s holding company. This move came at a nominal cost to Epstein, despite both Wexner and Kessler having already invested billions into the project.
+
+94. Wexner even let Epstein build a 10,000 square foot home on Wexner's personal estate within the New Albany development. Epstein, Kessler, Wexner, and John G. were all property owners (and neighbors) in this new and exclusive community.
+
+95. Epstein's connections to Columbus continued to develop — in fact, one article notes:
+
+Mr. Epstein became ubiquitous in Ohio. His black book of contacts filled up with phone numbers with Columbus's 614 area code. That included dozens of numbers for Mr. Wexner, his personal staff and L Brands executives — even a couple of local doctors. Mr. Epstein, who would fly in and out of Columbus on his private plane, became a fixture at Mr. Wexner's parties and an annual fund-raiser for the Wexner Center for the Arts, which included a luncheon at the billionaire's home.
+
+Mr. Epstein became deeply involved in Mr. Wexner's upscale realestate development in New Albany, about 15 miles outside Columbus. He set up shop in the same downtown Columbus skyscraper as Jack Kessler.
+
+96. This same group of the Columbus elite helped Dimon become CEO of Bank One in 2000. The Bank One board of directors that appointed Dimon included Kessler, who knew Epstein from the New Albany project. Former Bank One board members and executives including
+
+<sup>34</sup> M.
+
+Wexner and John G. had New Albany property neighboring Epstein. And the Columbus elite that did business with Bank One ran in the same social circles as Epstein.
+
+## C. Bank One Merges with First USA and First Chicago
+
+97. In 1997, John B. a native of Columbus, Ohio and the son of John G. =, the founder of Banc One Corporation (which later became Bank One), served as Bank One's Chairman and CEO. As the 1990s drew to a close, Bank One undertook a sequence of significant, high-profile mergers that redefined its corporate identity.
+
+98. In January 1997, Bank One agreed to merge with Texas-based First USA Bank. Following the closing of this transaction, in 1998, Bank One embarked on another significant merger, this time with First Chicago Bank. While completing the First Chicago deal, John B. was secretly meeting with Dimon in an attempt to bring him to Bank One as his number two.
+
+99. At the time, John B. was fully aware of Epstein's dealings in Ohio and with Wexner and Kessler, his Bank One colleagues who had worked with Epstein on creating the New Albany development.35 Additionally, his father owned property in the New Albany development along with Wexner, Kessler, and Epstein.
+
+100. Unfortunately for John B. =, Bank One suffered a series of adverse financial results, leading to his resignation as CEO and Chairman in December 1999. This void in leadership lead to speculation that Dimon would step in to lead Bank One, having recently been fired from Citigroup.
+
+<sup>35</sup>The Real COLUMBUS MONTHLY Feb. 9. 2014. 11:01 PM)
+
+101. Indeed, the New York Post wrote: "John stepped down as CEO of Banc One, the Ohio based superregional bank. Dimon's name leapt to the top of the list of possible successors. But as one bank analyst pointed out to Bull's Eye, `Why would Jamie want to move to Ohio? He's a New York boy."'
+
+## D. Dimon's Move to New York and Into the Midwest Power Circle
+
+102. The New York Post's skepticism proved misguided. In early 2000, Dimon was vying for the CEO position at Bank One. Dimon's fate rested in the hands of a group of individuals like Kessler, who would not only shape his forthcoming leadership trajectory but also, as discussed above, were already quite familiar with the comings and goings of Epstein, who had become "ubiquitous in Ohio."
+
+103. Following Dimon's interview for the role of CEO at Bank One, Kessler was in favor of hiring Dimon, stating, "He's just a fabulous leader. He's the best banker in the country, there's no question."36 Crown, one of the new Bank One directors with ties back to Robert Maxwell through his family link to General Dynamics, stated that the CEO Search Committee narrowed the search to two candidates, and that: "Jamie met with the board and made a very convincing presentation about where he would focus his energy in the beginning. It was clear he had seen this movie before. He had the experience of cutting costs and bringing organizations together, something we clearly needed."37
+
+<sup>36</sup> CEO Jack Kessler: Local Visionary: It's How You Treat People, COLUMBUS DISPATCH (Aug. 24, 2014, 12:01 AM), https://www.dispatch.com/story/business/2014/08/24/ceo-jack-kesslerlocal-visionary/23336557007/.
+
+<sup>37</sup> Whitney Crowning the Wall Street. UNLIMITED HANGOUT (April 27. 2023),
+
+Paul W. Marshall & Todd H. Thedinga, Jamie Dimon and Bank One (A), Harvard Business School Case 804-107, (Dec. 2003, rev. July 2012).
+
+104. Crown would go on to serve as head of JPM's risk committee during the Epstein saga. Despite a massive failure in his role, Crown continued to serve on the Board, with his directorship spanning nearly two decades.
+
+105. Wexner was no longer on the board of Bank One when Dimon arrived, and it is unclear if Dimon ever personally knew of or interacted with Epstein during that time. However, it is clear that Wexner, Kessler, Crown, and the McCoys were very much connected to Epstein's dealings in Ohio (including, of course, the New Albany project). Considering Epstein's consistent involvement with the Columbus business elite, it is fair to infer that Dimon, as the CEO of Bank One, with a board populated with Columbus's business elite, was aware of Epstein and likely crossed paths with him, at the least. Indeed, in a 2014 interview, Kessler referred to Dimon's affinity for Columbus, Ohio, stating, "Jamie loves it here because he said the work ethic is so good. He said he'd move everybody here if he could."38
+
+106. In January 2004, Bank One announced its acquisition by JPM for \$58 billion. The initial announcement did not envisage Dimon assuming the top position. According to the initial deal press release: [T]he newly merged entity was to be led by William B. M, 60, the existing chairman and chief executive of J.P. Chase. James Dimon, 47, then the chairman and chief executive of Bank One, was slated to become president and chief operating officer of the combined company.39 Fortunately for Dimon, his colleagues from Bank One had no plans to operate under leadership for long.
+
+<sup>38</sup> CEO Jack Kessler: Local Visionary: It's How You Treat People, COLUMBUS DISPATCH (Aug. 24, 2014, 12:01 AM), https://www.dispatch.com/story/business/2014/08/24/ceo-jack-kesslerlocal-visionary/23336557007/.
+
+<sup>39</sup> Andrew R. Sorkin & Landon Jr., J.P. Chase to Acquire Bank One in \$58 Billion Deal, N.Y. TIMES (Jan. 14, 2004), https://archive. is/202 10502192034/https://www.nytimes.com/2004/01/14/business/jp-achase-to-acquire-bank-one-in-58-bill ion-deal .html#selection-613.22-613.379.
+
+107. Only six months after closing the merger, Dimon was invited by the Board to take over as CEO of the combined company, and a short time thereafter he took on the role of Chairman. The directors who moved from the Bank One board to the JPM Board — Kessler, Crown, Stephen , Robert Lipp, Richard Manoogian, and David Novak — helped Dimon rise to the Company's CEO role.
+
+108. Dimon's tenure as CEO of JPM has been rife with management failures. A 2020 article raised a troubling question: "Why hasn't JPMorgan Chase's Board sacked Jamie Dimon as the bank accumulated five felony counts?" The piece recognizes that Dimon has not forgotten who afforded him the opportunity to become CEO, and the connection with Bank One continues to exert a significant influence on JPM's current board. The author responds to this question with: "Turns out Jamie Dimon has been taking very good care of the Directors on his Board and they have been taking very good care of Dimon — turning him into a billionaire, notwithstanding the worst criminal record of any major bank in the history of the United States.nm
+
+# IV. JPM PURSUES EPSTEIN
+
+# A. Onboarding Epstein As A Client
+
+109. Epstein's association with JPM began in 1998. In 2000, the Company entrusted the task of managing Epstein as a client to Staley, the then-new head of JPM's private banking division. Staley has explained that, when he was told to work with Epstein, he was specifically advised to "get to know him." The head of a global bank's private banking division presumably is not tasked with "getting to know" all of the bank's private bank clients.
+
+<sup>4°</sup> Pam Martens & Russ Martens, If You're Baffled As To Why JPMorgan Chase's Board Hasn't Sacked Jamie Dimon as the Bank Racked Up 5 Felony Counts — Here's Your Answer. WALL ST. ON PARADE: A CITIZEN GUIDE TO WALL ST. (Oct. 12, 2020), https://wallstreetonparade.com/2020/ Wif-youre-baffled-as-to-why-jpmorgan-chases-boardhasnt-sacked-jamie-dimon-as-the-bank-racked-up-5-felony-counts-heres-your-answert
+
+110. What began as Staley's professional endeavor to build a relationship with Epstein transitioned into a personal one, as discussed below in more detail. By 2003, it would become very quickly apparent to Staley that doing business with Epstein would include a level of reputational and legal risk unlike anything JPM had ever or should ever accept.
+
+111. As previously noted, JPM, like any major financial institution, has a duty to perform a high degree of due diligence on the individuals it does business with. Indeed, that duty should hold even greater importance when a new client like Epstein, who claims to managing billions of dollars for world elite, has little to no digital or public footprint. Moreover, Epstein's onboarding should have revealed his involvement with a slew of shady characters and financial dealings.
+
+112. For instance, if JPM even conducted this most rudimentary due diligence prior to onboarding Epstein as a client they would have learned that he departed Beams Stems under a shadow of financial inpropriety and was connected to Hoffenberg and the Towers Ponzi scheme. Those two connections alone should have warranted escalating Epstein to senior management or the JPM risk committee.
+
+## B. 2003 Vanity Fair Article Raises Major Concerns About Epstein
+
+113. In March 2003, Vicky of Vanity Fair published an article entitled "The Talented Mr. Epstein.'TM' The piece initially spotlights Epstein's roster of high-profile admirers and clients, including Wexner, Bill Clinton, Prince Andrew, and Alan Dershowitz. However, the article simultaneously carries a more sinister undertone, which should have raised alarm bells for anyone conducting business with Epstein. The following are several points from the article that should have set off significant concerns across JPM about its client:
+
+<sup>41</sup> Vicky The Talented Mr. Epstein, VANITY FAIR (Mar. I, 2003), https://www.vanityfair.cominews/2003/03/jeffrey-epstein-200303.
+
+- "He's reckless," says a former business associate, "and he's gotten more so. Money does that to you. He's breaking the oath he made to himself — that he would never do anything that would expose him in the media."
+- According to S.E.C. and other legal documents unearthed by VANITY FAIR, Epstein may have good reason to keep his past cloaked in secrecy: his real mentor, it might seem, was not Leslie Wexner but Steven Jude Hoffenberg, 57, who, for a few months before the S.E.C. sued to freeze his assets in 1993, was trying to buy the New York Post. He is currently incarcerated in the Federal Medical Center in Devens, Massachusetts, serving a 20-year sentence for bilking investors out of more than \$450 million in one of the largest Ponzi schemes in American history.
+- In 1987, Hoffenberg, according to sources, set Epstein up in the offices he still occupies in the Villard House, on Madison Avenue, across a courtyard from the restaurant Le Cirque. Hoffenberg hired his new protégé as a consultant at \$25,000 a month, and the relationship flourished. "They traveled everywhere together— on Hoffenberg's plane, all around the world, they were always together," says a source. Hoffenberg has claimed that Epstein confided in him, saying, for example, that he had left Bear Steams in 1981 after he was discovered executing "illegal operations."
+- Hoffenberg claimed in a 1993 hearing before a grand jury in Illinois that Epstein was the "technician" at Towers, executing illicit schemes, although, having no broker's license, he had to rely on others to make the trades.
+- Epstein, according to Hoffenberg, also came up with a scheme to manipulate the price of Emery Freight in an attempt to minimize the losses that occurred when Hoffenberg's bid went wrong, and the share price began to fall. This was alleged to have involved multiple clients' accounts controlled by Epstein.
+- Several of Epstein's Bear Steams contemporaries recall that Epstein left the company very suddenly. Within the company, there were rumors that the executive committee asked that Epstein resign after his two supporters, Ace Greenberg and Jimmy Cayne, were outnumbered.
+- In 1998, the U.S. Attorney sued Epstein for illegally subletting the former home of the deputy consul general of Iran to attorney Ivan Fisher and others. Epstein paid \$15,000 a month in rent to the State Department, but he charged Fisher and his colleagues \$20,000. Though the exact terms of the agreement are sealed, the court ruled against Epstein.
+- Currently, Citibank is suing Epstein for defaulting on loans from its private-banking arm for \$20 million. Epstein claims that Citibank "fraudulently induced" him into borrowing the money for investments. Citibank disputes this charge.
+
+## C. Epstein Brokers JPM's Purchase of Highbridge Capital And Helps Put JPM Executives on the Board of the Robin Hood Foundation
+
+114. Even if the 2003 Vanity Fair article never came to Defendants' attention and, as a result, they were unaware of Epstein's true character at the time, there is a deal from the early 2000s leaving any such claim of unfamiliarity with Epstein implausible.
+
+115. The Epstein private jet flight logs, spanning from 1990 to 2005, have received considerable media coverage due to the inclusion of names of former presidents and other prominent figures. However, less publicly recognized names, such as that of Eva ('a"), have managed to elude intensive scrutiny. Currently a practicing physician, is the former Miss Sweden, a Miss Universe Contestant, and, from at least the 1980s to the early 1990s, was Epstein's girlfriend.
+
+116. In 1994, married Glenn the co-founder of both Highbridge Capital ("Highbridge"), an alternative asset management firm, and the non-profit The Robinhood Foundation. Epstein reportedly invested millions of dollars into Highbridge in 1998, and it is possible that Epstein himself introduced and
+
+117. One of Epstein's most prominent accusers, , alleged in her lawsuit against Ghislaine Maxwell that in 2001, Ghislaine Maxwell had directed her to have sex with even though he had been married since 1994 and was only 16.
+
+118. Just a few years following this incident, in 2004, Epstein allegedly facilitated a meeting between Staley and to broker the sale of Highbridge to JPM for a majority interest valued at over \$1 billion.42 As reported by The Telegraph, "Epstein personally introduced the two men while Staley was head of the private bank at JP M. JP later purchased
+
+<sup>42</sup>A. Giannone, JPMorgan Buys Rest of Highbridge, REUTERS (June 11, 2009, 9:43 AM), https://www.reuters.com/article/us-jpmorganchase-highbridge-idUSTRE55A3PX20090611.
+
+Highbridge Capital in a \$1bn deal that enhanced Staley's status at the bank — and netted Epstein a fee of \$10m."43
+
+119. JPM now suggests that Staley somehow concealed Epstein's name and relationship with the bank from his superiors, Dimon and the Board itself. However, it is unlikely that a financial institution like JPM would approve a transaction exceeding a billion dollars without instituting some sort of top-level due diligence review.
+
+120. Highbridge was not the only conduit through which Epstein leveraged to extend his influence over key members at JPM. Two prominent figures in the Epstein saga, Staley and Erdoes, both served on the board of New York City children's charity, The Robinhood Foundation. Founded by in the early 1980s, the charity also currently has Kristen Lemkau, the CEO of U.S. Wealth Management for JPM, serving as the co-chair of the organization's leadership council. Following Epstein's arrest in 2019, The Robinhood Foundation faced intense public scrutiny for its connections to Epstein, and for allowing Staley to remain on its board.
+
+121. To truly comprehend the extent of involvement by and within Epstein's network of enablers, it is instructive to examine their actions following Epstein's 2008 conviction as a pedophile. As Business Insider revealed:
+
+> The Dubins invited Epstein to their Palm Beach home for Thanksgiving dinner in 2009. In an email to Epstein's probation officer, Eva wrote, "I am 100% comfortable with Jeffrey Epstein around my children," while acknowledging Epstein was convicted of procuring a minor for prostitution. At the time, the couple's three kids were underage.'
+
+<sup>43</sup> Helen Cahill, Jeffrey Epstein Scandal Casts A Shadow Over Glittering New York Charity, TELEGRAPH (Jan. 2, 2022 3:00 PM), https://www.telegraph.co.uldbusiness/2022/01/02/jeffreyepstein-scandal-casts-shadow-glittering-new-york-charity/.
+
+<sup>&</sup>quot; Kate Briquelet & Michael Daly, NYC Power Couple's Says Swedish Teen Told Him of Epstein Island Horrors, DAILY BEAST (Aug. 9, 2019, 3:46 PM), https://www.thedailybeast.com/jeffrey-epstein-scandal for-glenn-and-eva-M-saysswedish-teen-told-him-she-was-pressured-for-sex.
+
+122. Merely months prior to the Thanksgiving dinner at the residence, Epstein had assisted Staley and JPM in finalizing the purchase of the remaining stake in Highbridge, which at the time had assets under management of approximately \$21 billion.45 Considering the size of the initial investment and eventual purchase, the Highbridge deal would have a certainly been a material transaction that warranted due diligence from the highest levels of JPM.
+
+## D. Epstein Brokered a Meeting Between JPNI and the Prime Minister of Israel
+
+123. Between 2009 and 2011, Epstein helped Staley schedule meetings for Dimon to meet with Israeli Prime Minister Netanyahu, Microsoft founder Bill Gates, and Britain's Prince Andrew. Despite Epstein and Staley's collaboration in setting up these meetings with such high-profile individuals, Dimon purportedly testified that he never heard of Epstein until 2018 or 2019.46 Dimon's unequivocal assertion rings untrue.
+
+124. It is almost unfathomable that the CEO and Chairman of JPM would not be aware of how an in-person meetings with some of the world's most prominent leaders was arranged, including who set it up.
+
+<sup>45</sup>A. Giannone, JPMorgan Buys Rest of Highbridge, REUTERS (June 11, 2009, 9:43 AM), https://www.reuters.com/article/us-jpmorganchase-highbridge-idUSTRE55A3PX20090611.
+
+<sup>46</sup>Kate Briquelet, Epstein Connected JPMorgan Exec to Netanyahu, Prince Andrew, DAILY BEAST (June 20, 2023, 3:30 PM), https://archive.is/20230620224740/https://wvvw.thedailybeast.com/jeffrey-epstein-epsteinhooked-up-jpmorgan-exec-jes-staley-with-benjamin-netanyahu-prince-andrew-emailsshow#selection-1243.0-1243.59.
+
+### V. EPSTEIN REMAINS A JPM CLIENT WHILE THE TRUTH ABOUT HIM COMES INTO THE PUBLIC EYE
+
+### A. The Highest Reaches of JPM Unambiguously Knew that Epstein Was a Convicted Sex Offender Accused of Continuing Sexual Abuse
+
+125. In March 2005, press reports emerged reporting that Epstein paid a 14-year-old girl in Palm Beach, Florida for a "massage" and then molested her. Following the release of these allegations, a number of underage girls — many of them high school students — told police that Epstein also hired them to give sexual massages.
+
+126. In July 2006, Epstein was arrested in Palm Beach, Florida, after a grand jury indicted him for soliciting a minor for prostitution. JPM — including Staley and Erdoes — were immediately aware of Epstein's arrest and his pedophilia. For instance, on August 27, 2006, Staley emailed Erdoes: "Last night went to the Huggy Bear concert. The age difference between husbands and wives would have fit in well with Jeffrey. What a joke.'
+
+127. Epstein's arrest received national news coverage, leaving no doubt about the heinous nature of his crimes. For instance, on September 3, 2006, The New York Times reported:
+
+> In the summer and autumn of last year, when most of the mansions here stood empty behind their towering hedges, the police stealthily watched one at the end of a waterside lane. They monitored the comings and goings of its owner's private jet, subpoenaed his phone records and riffled through his trash.
+
+> The owner was Jeffrey Epstein, 53, an intensely private New York money manager with several billionaire clients. Months earlier, the stepmother of a 14-year-old girl told the Palm Beach police that a wealthy older man, whom the girl later identified as Mr. Epstein, might have had inappropriate sexual contact with her.
+
+> In sworn statements to the police, the 14-year-old and other teenage girls said a friend had arranged for them to visit Mr. Epstein's home
+
+<sup>47</sup> Deposition of James Dimon, Government of the United States Virgin Islands v. JP Chase Bank, N.A., 1:22-cv-10904-JSR (S.D.N.Y. May 26, 2023) ("Dimon Tr.") at 133-34.
+
+and give him massages, usually in their underwear, in exchange for cash.
+
+Most of the girls, according to the police, said Mr. Epstein had masturbated during the massages, and a few said he had penetrated them with his fingers or penis. They identified him in photos and accurately described the inside of his home. Some recalled that his employees had fed them snacks or rented them cars.
+
+Mr. Epstein pleaded not guilty in August to the crime he was ultimately charged with, soliciting prostitution. But at a time when prosecutors around the nation have become increasingly severe in dealing with people accused of sex offenses, the case has raised questions about whether Mr. Epstein's prominence won him preferential treatment.
+
+By the account of the police, they found probable cause to charge Mr. Epstein with much more serious offenses: one count of lewd and lascivious molestation and four counts of unlawful sexual activity with a minor.08
+
+128. The fact of Epstein's ongoing relationship with JPM was hardly a secret within the bank. Indeed, JPM employees — including Erdoes — circulated this New York Times article internally. The first line in the email read: "Did you see this article in the NYT this weekend? Lovely guy to work with."49
+
+129. On October 17, 2006, the Company's Global Corporate Security Division designated Epstein a "high-risk client" because "[s]everal newspaper articles were found that detail the indictment of Jeffrey Epstein in Florida on felony charges of soliciting underage prostitutes."59 As a result, JPM determined not to "proactively solicit new investment business from Mr. Epstein."51
+
+<sup>48</sup>Abby Goodnough, Questions of Preferential Treatment Are Raised in Florida Sex Case, N.Y. TIMES (Sept. 3, 2006), https://www.nytimes.com/2006/09/03/us/03epstein.html.
+
+<sup>49</sup> Dimon Tr. at 98.
+
+<sup>5°</sup>Dimon Tr. at 127-28.
+
+Si Dimon Tr. at 18-19.
+
+130. Having so designated Epstein, internal review and approval processes were necessarily triggered. Nevertheless, the Company continued to retain Epstein as a client.
+
+131. Knowledge of Epstein's crimes (and his associated massive cash withdrawals to fund his sexual abuse) extended to the top of JPM's organization. At her recent deposition, Erdoes admitted that the Company was aware by 2006 not only that Epstein was abusing women and underage girls, but that Epstein paid these victims in cash. <sup>52</sup> This was the same year that a JPM Rapid Response Team noted that Epstein routinely withdrew \$40,000 to \$80,000 in cash from his accounts several times each month, and more than \$750,000 per year."
+
+132. Erdoes knew Epstein personally. Indeed, Erdoes visited Epstein at his New York home in both 2011 and 201354 Erdoes is also reported to have exchanged "dozens of emails" with Epstein, including with regard to a charitable fund that JPM considered launching together with Epstein."
+
+133. In June 2008, Epstein pled guilty to soliciting a minor for prostitution. As part of the plea agreement, Epstein was sentenced to an I8-month jail term, followed by one year of community confinement, and was required to register as a sex offender. As with his 2006 arrest, Epstein's plea deal received national media attention (and concomitant attention within JPM).56
+
+<sup>52</sup> IISVICompl.¶ 92.
+
+<sup>53</sup> USVICompl.¶ 92.
+
+<sup>54</sup> IChadeeja Safdar & David Benoit, JPMorgan's Ties to Jeffrey Epstein Were Deeper That the Bank Has Acknowledged, WALL ST. J. (Apr. 21, 2023, 3:55 PM), https://www.wsj.com/articlesipmorgan-jeffrey-ep.- 525 febe3?mod—Searchresults\_pos9&page=1.
+
+<sup>55</sup> Id.
+
+<sup>56</sup> See, e.g., Samuel Goldsmith, Jeffrey Epstein Pleads Guilty to Prostitution Charges, N.Y. POST (June 30, 2008, 5:04 PM), https://nypost.com/2008/06/30/jeffrey-epstein-pleads-guilty-toprostitution-chargest
+
+134. According to JPM, "[p]er bank policy, felons are considered high risk and require additional approval."57
+
+135. Epstein's guilty plea led some JPM employees to assume that the Company would immediately terminate its relationship with the now-convicted sex offender. As of July 15, 2008, a JPM Rapid Response Team document indicated that "Catherine [Keating, the CEO of the Company's Private Bank] will go back to Jes [Staley, then the CEO of JPM's Asset Management Division] to tell him we are uncomfortable with Epstein and do not want to go to [Stephen] Cutler [JPM's General Counsel] for approval."58 In other words, the most senior members of the Private Bank knew that trying to retain Epstein as a client was an absurd ask to the General Counsel, given all of the red flags surrounding Epstein.
+
+136. The next month, in August 2008, a JPM employee wrote that she "would count Epstein's assets as a probable outflow for '08 (\$120mm or so?) as I can't imagine it will stay (pending Mamie) Dimon review)."59 The fact that Epstein's account status was expected to be presented to Dimon suggests either that it was (as per known internal protocols) or that the matter was resolved in favor of keeping Epstein without forcing Dimon to leave a paper trail of his involvement in the matter.
+
+137. Thus, a plausible conclusion arising from that August 2008 email is that Dimon the Company's CEO and Chairman - was aware of Epstein's crimes by that time and would decide whether the Company would retain Epstein as a client. Yet, the bank chose to keep doing business with Epstein.
+
+<sup>&</sup>quot; USVJ Compl. 1 50.
+
+<sup>58</sup> Dimon Tr. at 138.
+
+<sup>&</sup>quot; USW Comp1.1 51.
+
+138. In 2009, a once-secret 2008 non-prosecution agreement between Epstein and the United States became public. It revealed allegations that Epstein may have used interstate commerce to induce minors to engage in prostitution, engaged in illicit sexual conduct with minors, and trafficked minors.
+
+139. Epstein's guilty plea in 2008, jail sentence, and additional allegations of sex crimes did not put an end to his relationship with Staley, who allegedly participated in Epstein's crimes.60 Between 2008 and 2013, Staley used his Company email account to exchange 1,200 emails with Epstein:" And, both before and after Epstein's arrest and prison sentence, Staley frequently called Epstein's Palm Beach, Florida home, according to the below messages included in the complaint in the Jane Doe Action (including at least one call when Staley called with Wexner):62
+
+<sup>60</sup> Doe 1 v. Deutsche Bank Aktiengesellschaft, 2023 WL 3167633, at •4 n.3 (S.D.N.Y. May 1, 2023).
+
+<sup>61</sup> USV/Comp1.1 53.
+
+<sup>62</sup> Jane Doe Compl. ¶¶ 148-49.
+
+| IMPORTANT MESSAGE                                                                                                                            |                                                                                                                                                                | IMPORTANT MESSAGE                                                                                                                                        |                                                                                                                            |
+|----------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------|
+| FOR <u>JAN 4</u><br>DATE <u>03/10/05</u> TIME <u>4:20 AM</u><br>M <u>Jas Staley</u><br>OF <u>6312830188</u><br>PHONE MODEL <u>6312830188</u> | TELEPHONED PLEASE CALL<br>CAME TO SEE YOU <input checked="" type="checkbox"/> WILL CALL AGAIN<br>WANTS TO SEE YOU RUSH<br>RETURNED YOUR CALL SPECIAL ATTENTION | FOR <u>Mr. J.P.</u><br>DATE <u>12/21/04</u> TIME <u>10:27 AM</u><br>M <u>Jas Staley</u><br>OF <u>(212) 837-2375</u><br>PHONE MODEL <u>(212) 837-2375</u> | TELEPHONED PLEASE CALL<br>CAME TO SEE YOU WILL CALL AGAIN<br>WANTS TO SEE YOU RUSH<br>RETURNED YOUR CALL SPECIAL ATTENTION |
+| MESSAGE                                                                                                                                      |                                                                                                                                                                | MESSAGE                                                                                                                                                  |                                                                                                                            |
+| <br>                                                                                                                                         |                                                                                                                                                                | <br>                                                                                                                                                     |                                                                                                                            |
+| SIGNED <u>R</u>                                                                                                                              |                                                                                                                                                                | SIGNED <u>R</u>                                                                                                                                          |                                                                                                                            |
+
+  
+
+| IMPORTANT MESSAGE                                                                                                                                  |                                                                                                                            | IMPORTANT MESSAGE                                                                                                                                          |                                                                                                                            |
+|----------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------|
+| FOR <u>J.P.</u><br>DATE <u>3/15/05</u> TIME <u>8:02 AM</u><br>M <u>Jas Staley</u><br>OF <u>(212) 744-0770</u><br>PHONE MODEL <u>(212) 744-0770</u> | TELEPHONED PLEASE CALL<br>CAME TO SEE YOU WILL CALL AGAIN<br>WANTS TO SEE YOU RUSH<br>RETURNED YOUR CALL SPECIAL ATTENTION | FOR <u>MR. EPSTEIN</u><br>DATE <u>05/21/04</u> TIME <u>6:49 PM</u><br>M <u>JES STALEY</u><br>OF <u>(212) 744-0770</u><br>PHONE MODEL <u>(212) 744-0770</u> | TELEPHONED PLEASE CALL<br>CAME TO SEE YOU WILL CALL AGAIN<br>WANTS TO SEE YOU RUSH<br>RETURNED YOUR CALL SPECIAL ATTENTION |
+| MESSAGE                                                                                                                                            |                                                                                                                            | MESSAGE                                                                                                                                                    |                                                                                                                            |
+| <br>                                                                                                                                               |                                                                                                                            | <br>                                                                                                                                                       |                                                                                                                            |
+| SIGNED <u>T.</u>                                                                                                                                   |                                                                                                                            | SIGNED <u>SA02834</u>                                                                                                                                      |                                                                                                                            |
+
+| IMPORTANT MESSAGE                                                                                                                                         |                                                                                                                            | IMPORTANT MESSAGE                                                                                                                                  |                                                                                                                            |
+|-----------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------|
+| FOR <u>MR. EPSTEIN</u><br>DATE <u>1/11/05</u> TIME <u>6:27 AM</u><br>M <u>JES STALEY</u><br>OF <u>(207) 912-7145</u><br>PHONE MODEL <u>(207) 912-7145</u> | TELEPHONED PLEASE CALL<br>CAME TO SEE YOU WILL CALL AGAIN<br>WANTS TO SEE YOU RUSH<br>RETURNED YOUR CALL SPECIAL ATTENTION | FOR <u>J.P.</u><br>DATE <u>1/11/05</u> TIME <u>6:27 AM</u><br>M <u>Jes Staley</u><br>OF <u>(207) 912-7145</u><br>PHONE MODEL <u>(207) 912-7145</u> | TELEPHONED PLEASE CALL<br>CAME TO SEE YOU WILL CALL AGAIN<br>WANTS TO SEE YOU RUSH<br>RETURNED YOUR CALL SPECIAL ATTENTION |
+| MESSAGE                                                                                                                                                   |                                                                                                                            | MESSAGE                                                                                                                                            |                                                                                                                            |
+| <br>                                                                                                                                                      |                                                                                                                            | <br>                                                                                                                                               |                                                                                                                            |
+| SIGNED <u>R</u>                                                                                                                                           |                                                                                                                            | SIGNED <u>R</u>                                                                                                                                    |                                                                                                                            |
+
+|                          | ANLMESSAGE  |
+|--------------------------|-------------|
+| Fr C-11                  | -27CW a 4SE |
+| Can Ma ICU               | Oill•Mill   |
+| r inellte 00111•10 OM MI | ail MON     |
+| Pineal. 1001.1•A         | S CSI van  |
+
+140. In December 2008, Epstein and Staley discussed Staley visiting Epstein at his Florida home. Although Epstein was not going to be in Palm Beach at the time, Epstein invited Staley to use his house." In early January 2009, around the time that Staley was staying at Epstein's Palm Beach house, Epstein wired \$2,000 from his JPM account to a woman with an Eastern European surname (many of the women that Epstein trafficked were from Eastern Europe)."
+
+141. Later in 2009, Epstein and Staley again discussed getting together, this time in London. In late August 2009, Epstein asked Staley whether he would need anything while he was in London. Staley said yes." Just two days later, Epstein again used his JPM account to wire \$3,000 to the same woman with an Eastern European surname he had paid while Staley was in Palm Beach."
+
+142. Just months later, in November 2009, while Epstein was already in jail, Staley again took advantage of Epstein's hospitality — this time at Epstein's now-infamous private island, Little
+
+<sup>63</sup> US VI Compl. ir 54.
+
+<sup>64</sup> USV/ Compl. ¶ 54.
+
+<sup>65</sup> US V/ Compl. i 55.
+
+<sup>&</sup>quot; USW Comp1.1 55.
+
+St. James, Virgin Islands. While there, Staley emailed Epstein: "So when all hell breaks lo[o]se, and the world is crumbling, I will come here, and be at peace. Presently, I'm in the hot tub with a of wine. This is an amazing place. Truly amazing. Next time, we're here together. I owe you much. And I deeply appreciate our friendship. I have few so profound."67
+
+143. The following month, Staley made clear that he was fully aware of the risk that his ongoing relationship with Epstein posed to him. On December 4, 2009, Staley met with Epstein in New York, and then emailed him: "I realize the danger in sending this email. But it was great to be able, today, to give you, in New York City, a long heartfelt, hug."68
+
+144. Despite recognizing it, Staley continued to disregard the "danger" of Epstein. The next day and later in December 2009, Epstein sent pictures of young women to Staley, to which Staley responded with cryptic commentary.69 Staley again visited Little St. James the following month, in January 2010.7° Later that year, in July 2010, Staley had the following exchange with Epstein via email, strongly suggesting that Epstein was procuring victims for Staley:7'
+
+Stale Maybe they're tracking u? That was fun. Say hi to Snow
+
+Epstein: [W]hat character would you like next?
+
+Staley: Beauty and the Beast.
+
+Epstein: [W]ell one side is available.
+
+145. Also in July 2010, a news article from The Daily Beast reported that, since his release from jail, Epstein had settled more than a dozen lawsuits brought by underage girls, and at
+
+<sup>67</sup> USV/Compl. 1 56.
+
+<sup>68</sup> US VI Compl. I 57.
+
+<sup>69</sup> USW C,ompl. y¶ 58-59.
+
+<sup>7°</sup> USW Compl. 1 60.
+
+<sup>71</sup> US V/ Comp1.1 61.
+
+least seven victims received well over SI million. <sup>72</sup> That same article noted allegations that Epstein was involved with Eastern European women in particular and that a modeling agency he helped fund brought "young girls . .. often from Eastern Europe" to the United States on Epstein's private jets.73
+
+146. JPM was aware of these allegations. Memos from JPM compliance meetings specifically referenced articles regarding a federal investigation into "whether a modeling agency run by a friend ... fed his appetite for underage foreign girls" and noted that "Epstein was known to fly young women from Eastern Europe to Palm Beach where they'd massage him, among other services."74
+
+147. In an internal email, an employee in the Company's risk management division referred to "new allegations of an investigation related to child trafficking," and asked whether JPM was "still comfortable with this client who is now a registered sex offender.s75 Other JPM compliance employees decided that Epstein "should go."76 But reflecting the Company's fundamental attitude towards Epstein's crimes, a different JPM risk management employee dismissed these disturbing reports as routine: "In my short tenure working on the account these stories pop up including these from the summer."77
+
+<sup>72</sup>Jeffrey Epstein Pedophile Billionaire and His Sex Den, DAILY BEAST (July 22, 2010 7:46 PM), https://www.thedailybeast.comijeffrey-epstein-pedophile-billionaire-and-hissex-den.
+
+<sup>73</sup> Id.
+
+<sup>74</sup> USVI Comp1.1 101.
+
+<sup>75</sup> USVICompl. 1 45.
+
+<sup>76</sup> USVI Compl. 1 98.
+
+<sup>77</sup> USVIComp1.1 45.
+
+148. In December 2010, JPM granted Epstein a new \$50 million line of credit.78
+
+149. The next year, in January 2011, JPM once again was made keenly aware of yet more allegations of human trafficking against Epstein. And yet again, JPM brushed off the allegations. That month, the Company conducted a review of Epstein's accounts because a "few news stories during 2010 connect[ed] Jeffrey Epstein to human trafficking."79 According to the complaint in the USV/ Action, JPM's coverage team "met to discuss the situation and agreed to enhance monitoring and document a discussion with the client."B0
+
+150. Staley — Epstein's apparent co-conspirator and accomplice—was the JPM executive that the Company entrusted to hold this "discussion" with Epstein.81 According to the documentation of the discussion, Epstein claimed "there was no truth to the allegations" against him and "no evidence."82 JPM internally concluded that it would "continue to monitor the accounts and cash usage closely going forward."S3 The Company did not file a SAR.
+
+151. In March 2011, JPM's Global Corporate Security Division again internally reported that "[n]umerous articles detail various law enforcement agencies investigating Jeffrey Epstein for allegedly participating, directly or indirectly, in child trafficking and molesting underage girls.s80 This report also noted that Epstein had "settled a dozen civil lawsuits out of court from his victims regarding solicitation?"8S
+
+<sup>78</sup> USV/ Compl. 1 46.
+
+<sup>79</sup> US VI Compl. 1 47.
+
+<sup>80</sup> USV/ Compl. 1 47.
+
+<sup>8</sup>I USV/ Compl. 1 47.
+
+<sup>82</sup> US V/ Compl. 1 47.
+
+<sup>83</sup> US V/ Compl. 1 47.
+
+<sup>&</sup>quot; USV/ Compl. 1 48.
+
+<sup>85</sup> US V/ Compl. 1 48.
+
+152. This same March 2011 report also noted that the owner of a company named "MC2 Model Management and Jeffrey Epstein engaged in racketeering that involved luring in minor children for sexual play for money[,]" and that MC2 Model Management's owner was a "frequent passenger on Epstein's private jet and often visited Epstein in jail."" The March 2011 report also noted that Epstein paid MC2 Model Management SI million in 2005, and that it was "unknown if the money was given as a secret investment or payment for services as a procurer."S7
+
+153. MC2 Model Management's owner was Jean-Luc Brunel ("Brunel"), a model scout who faced allegations of sexual assault spanning three decades. Brunel allegedly groomed young females and partook in Epstein's sex trafficking ring. On December 16, 2020, prosecutors charged Brunel with rape of minors, but he died from an apparent suicide before his trial could proceed?
+
+154. Also in 2011, a senior JPM compliance official who reviewed the Company's relationship with Epstein warned that there was "Mots of smoke" and "Mots of questions" surrounding Epstein's criminal behavior.89 According to the complaint filed in the USW Action, these issues included that:"
+
+- Epstein "is alleged to be involved in the human trafficking ofyoung girls and law enforcement is also allegedly investigating his involvement in this activity."
+- "He is also an alleged personal associate of the CEO of the Investment Bank (Jes Staley)."
+
+<sup>&</sup>quot; USW Compl. 1 48.
+
+<sup>87</sup> USW Compl. 1 48.
+
+<sup>88</sup> Jeffrey Epstein associate Jean-Luc Brunel is found dead in a jail cell, NPR (Feb. 19, 2022, 12:20 PM), https://www.npr.org/2022/02/19/1081961087/Jeffrey-epstein-jean-luc-bruneldead.
+
+<sup>&</sup>quot; USV/ Compl. 1 98.
+
+<sup>9°</sup> USW Compl. 1 98 (emphases added) (alterations in original).
+
+- "AML Operations went to a [Private Bank] risk meeting late last week requesting that we exit this relationship."
+- "[W]hether Epstein is further exposed could have a potential serious impact."
+- "The one new concerning thing is the one article about the DOJ investigation is saying they brought under age girls to the US via a modeling agency M2 that is owned by a guy named Brand. Turns out the banker said today we extended Epstein a loan in relation to this modeling agency." The writer claims that the agency is "legit" and that "it would be hard for us to tell" if "girls were exploited via their contract or arrangement." The loan was a letter of credit provided by JPM to MC2 Model Management.
+- In 2004, Epstein sponsored private bank accounts and credit curds for two 18 year olds "that appear to be part of his inner entourage. One is mentioned in many of the recaps of the escapades as a willing participant and assistant when hosting visitors. She has received about 450,000 since opening from Epstein .... Both can be put in Palm Beach during 2004, by way of debit charges, which was when most allegations were from . . . . He did pay other girls, many models no huge amounts. Sugar Daddy!"
+- "His foundation account did pay donations to the Palm Beach Police Dept as reported just before the case started. The same foundation account did pay monies direct to models and payments direct to specialty schools (massage, culinary) and university's [sic] on behalf of models/aspiring actresses. Nothing was astronomical."
+- "His business accounts Fiduciary we saw no client activity. I know his biggest client, Wexner parted ways when he was convicted. His [Due Diligence Reports] say he manages a few private clients [sic] money but never says who. I would like to know if in fact he is managing anyone's money at this point or is it all his money. We saw no evidence of disbursements even in the rocky years 08-09. When the well to do were running to their mattresses, he did not have any distributions from his accounts at Bear or JP. He does have money at other institutions so maybe it happened there."
+
+155. On July 20, 2011, Cutler emailed Staley and Erdoes, among others, concerning
+
+Epstein, and wrote: "This is not an honorable person in any way. He should not be a dient."9I
+
+<sup>91</sup> Dimon Tr. at 181.
+
+The next day, July 21, 2011, Cutler emailed Erdoes again, writing about Epstein: "I would like to put it and hint behind us. Not a person we should do business with, period."92
+
+156. Yet, JPM continued doing business with Epstein, as well as his partners in crime. In August 2011, Ghislaine Maxwell applied to open a new account with JPM for a "personal recruitment consulting business."93 Internally, the Company's AML director asked: "What does she mean by personal recruitment?? Are you sure this will have nothing to do with Jeffrey? If you want to proceed, I suggest that we flag this as a High Risk Client."54
+
+157. In fact, the Company retained Epstein as a client well into 2013. John Duffy — who served as Vice Chairman of JPM and as the CEO of the Company's private bank for ultrawealthy clients — visited Epstein at his New York home in April 2013." Just one month later, the private bank that Duffy ran re-authorized Epstein to borrow up to S50 million against his accounts."
+
+158. At bottom, despite unequivocally knowing that Epstein was a serial sex offender, and despite the obviously suspicious nature of Epstein's activity with the Company, JPM took no corrective action against Epstein for years. Finally, later in 2013, the Company purportedly
+
+<sup>92</sup> Dimon Tr. at 184.
+
+<sup>93</sup> USW Compl. 149.
+
+<sup>&</sup>quot; USV/ Compl. ¶49.
+
+Khadeeja Safdar & David Benoit, JPMorgan's Ties to Jeffrey Epstein Were Deeper That the Bank Has Acknowledged, WALL ST. J. (Apr. 21, 2023 3:35 PM), https://www.wsj.com/articles/jpmorgan-jeffrey-a 525febe3?mod=Searchresults\_pos9&page=1.
+
+<sup>&</sup>quot; USW Compl. ¶70; Khadeeja Safdar & David Benoit, JPMorgan's Ties to Jeffrey Epstein Were Deeper That the Bank Has Acknowledged, WALL ST. J. (Apr. 21, 2023 3:35 PM), https://www.wsj.com/artieles/jpmorgan-jeffrey-ep.- 525febe3?mod=Searehresultspos98cpage=1.
+
+terminated its relationship with Epstein. That same year, Staley left the Company.B7 The U.S. Virgin Islands has alleged that JPM continued business with Epstein affiliated entities.
+
+### B. .Adequate Compliance Systems Plainly Should Have At Least Resulted in the Filings of SARs and Reporting to the Board
+
+159. As alleged above, JPM employees — including those at the highest reaches of the Company, such as Staley and Erdoes — knew Epstein was a felon convicted for sexual abuse, a pedophile who allegedly trafficked young girls from all over the world (including on his private plane), and regularly wired and withdrew large sums of cash from his JPM accounts. Those facts alone should have triggered the filing of SARs and reporting to the Board. Again, federal banking laws require a SAR filing in connection with:
+
+> Transactions conducted or attempted by, at, or through the bank . aggregating 15,000 or more, if the bank .. . knows, suspects, or has reason to suspect that the transaction": (a)"Inday involve potential money laundering or other illegal activity"; (b) "[i]s designed to evade the BSA or its implementing regulations"; or (c) "[hies no business or apparent lawful purpose or is not the type of transaction that the particular customer would normally be expected to engage in, and the bank knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction.98
+
+160. Nevertheless, upon information and belief, JPM never filed a SAR related to Epstein. And, according to the complaint filed in the USVI Action, it does not appear that JPM engaged in any investigation of the source of Epstein's funds."
+
+<sup>97</sup> Luc , Ex-JPMorgan executive Staley to be questioned under oath about Epstein ties, REUTERS (June 9, 2023, 1:08 PM), https://www.reuters.corn/legal/ex-jpmorgan-executive-staleybe-questioned-under-oath-about-epstein-ties-2023-06- 09/#:—:text—Staley')/0201eft%20JPMorgan%20in%202013,his%20role%20at%20the%20time.
+
+<sup>98</sup>Bank Secrecy Act / Anti-Money Laundering Examination Manual, Federal Financial Institutions Examination Council, at 60-61 (2006), available at https://www. ffiec.gov/pdUbsa\_aml\_examination\_manual2006.pdf.
+
+<sup>&</sup>quot; USW Compli 76.
+
+161. Moreover, according to Dimon's deposition testimony, between 2006 — when Epstein was arrested for soliciting a minor for prostitution — and 2013, the Board never discussed Epstein's relationship with JPM.100 Indeed, in connection with the Jane Doe Action, Dimon submitted a sworn answer to an interrogatory that, between 2000 and 2018, he received no information from any officer, director, employee, or agent of JPM concerning Epstein.101
+
+162. Dimon not only continues to profess ignorance, but he also seeks to deflect blame entirely from JPM. During his deposition, Dimon said, concerning a victim, "I hope she gets justice against the people who perpetrated the crime, which was not ns,"102 and later quipped, "we cannot do law enforcement's job."103 Of course, JPM interfered with law enforcement doing its job (and the Company affirmatively violated the law) by not filing a single SAR related to Epstein.
+
+163. Also at his deposition, Dimon testified that Epstein's cash activity would have been visible to JPM in real time.104 Had the Company focused on Epstein's specific transactions - some of which are discussed below in more detail — JPM should have filed SARs and provided specific updates to the Board.
+
+164. In total, between 2003 and 2013, at least 20 women trafficked and abused by Epstein were paid through JPM accounts.105 These women received payments, typically multiple payments, in excess of \$1 million collectively during this period.106 According to the complaint
+
+<sup>100</sup> Dimon Tr. at 53-54.
+
+<sup>1°1</sup> Dimon Tr. at 67-68.
+
+<sup>1°2</sup> Dimon Tr. at 211.
+
+<sup>103</sup> Dimon Tr. at 225-26.
+
+<sup>&</sup>quot;Dimon Tr. at 149.
+
+<sup>1°5</sup> USVI Compl. ¶ 42.
+
+<sup>1°6</sup> USV/ Compl. ¶ 42.
+
+in the USV/ Action, "among the recipients of these payments were numerous women with Eastern European surnames who were publicly and internally identified as Epstein recruiters and/or victims."107 For example, Epstein paid more than \$600,000 (including more than \$165,000 after Epstein's 2008 plea) to a woman who — according to news reports contained in JPM's due diligence reports — Epstein purchased at the age of 14.106 Like other women who received payments from Epstein, that victim listed Epstein's apartment on 66th Street in New York City as her address, which should have been a glaring red flag to the Company.109
+
+165. Epstein also withdrew more than \$775,000 in cash between 2003 and 2013 from JPM accounts, which is especially significant as Epstein was known to pay for "massages," or sexual encounters, in cash.' 10 Financial information evaluated in connection with the USV/ Action also reflects payments drawn from JPM accounts of nearly \$1.5 million to known recruiters, including to the MC2 Model Management (a company which, as discussed above, JPM compliance had flagged in 2011), and another \$150,000 to a private investigative firm.'"
+
+166. Epstein and/or his associates also made 95 foreign remittances with no known payee during this same time period — all transactions which JPM should have flagged and investigated.12 For example, Hyperion Air, Inc. ("Hyperion") — the Epstein-controlled company that owned Epstein's private jet used to traffic his victims — issued over \$547,000 in checks
+
+<sup>1°7</sup> USV/ Compl. ¶ 66.
+
+l°8 USV/Compl. ¶ 99.
+
+I" USV/ Compl. ¶ 66.
+
+10 USV/Compl. 1 42.
+
+<sup>&</sup>quot;' USV/Compl. ¶ 42.
+
+<sup>112</sup> USV/ Compl. ¶ 67.
+
+payable to cash purportedly for "fuel expenses when traveling to foreign countries."13 Additionally, between January 2012 and June 2013, Hyperion converted more than \$120,000 into foreign currency.114 Many of these cash withdrawals "either exceeded the \$10,000 reporting threshold or were seemingly structured to avoid triggering the reporting requirement."n5
+
+167. Epstein also used other entities under his control and with accounts at JPM, including his purported charitable organizations C.O.U.Q. Foundation and Enhanced Education, to funnel payments to his victims and associates.116 JPM seemingly did no due diligence on the nature of these various business entities, which appear to have no legitimate business purpose and, upon information and belief, were part of Epstein's criminal enterprise.
+
+168. For example, Epstein and/or his representatives "used the C.O.U.Q. Foundation account to pay \$29,464.66 to three young women, including two known victims, and over \$20,000 to a company called Phoenix Realty Home Inc."'"
+
+169. It is clear that JPM's compliance systems, at least between 2006 until Epstein's 2019 arrest, were grossly deficient and failed to comply with both banking laws and regulations and Delaware fiduciary duty law. As detailed above, there were screaming red flags concerning Epstein — including his conviction, innumerable press reports, various government investigations, and highly suspicious activity in his Company accounts — yet JPM did nothing about it, besides sitting on their hands until belatedly firing Epstein as a client. Simply put, that was plainly inadequate under the law.
+
+<sup>13</sup>USVI Compl. ¶ 67.
+
+<sup>114</sup> USV/ Compl. ¶ 67.
+
+<sup>115</sup> USV/Compl. ¶ 67.
+
+<sup>116</sup> USV/Compl. ¶ 68.
+
+I" USV/ Compl. ¶ 68.
+
+#### VI. A BROKEN AML COMPLIANCE SYSTEM: JPM "FAILED TO IDENTIFY SIGNIFICANT VOLUMES OF SUSPICIOUS ACTIVITY," IS ORDERED TO PAY \$350 MILLION IN FINES, AND PLEADS GUILTY TO TWO FELONY COUNTS
+
+170. In January 2014, JPM settled two felony violations of the BSA with the Department of Justice stemming from its failure to alert authorities to suspicious activity after red flags about Bernie Madoff's illegal conduct were raised at the bank.' i8 As part of the settlement agreement, JPM agreed to pay \$1.7 billion in penalties."9 Federal prosecutors noted that "the Madoff Ponzi scheme was conducted almost exclusively" through various accounts held at JPM.129 In fact, in the early 2010s, JPM's board of directors risk committee lacked any directors who had worked at a bank or as financial risk managers.<sup>121</sup>
+
+171. Additionally, the 0CC ordered JPM to pay a \$350 million fine for deficiencies in JPM's BSA and AML compliance programs. The penalty was based in part on JPM's failure to report suspicions about Bernie Madoff to U.S. law enforcement and regulators.
+
+172. Even after it faced these highly publicized penalties, JPM has continued its illicit conduct, servicing funds for notorious bad actors:
+
+- From 2003 through 2014, JPM handled hundreds of transactions totaling nearly \$2 billion for Dmytro Firtash, a Ukrainian oligarch who is wanted on criminal charges in the United States.I22
+
+<sup>&</sup>quot; 8 Ben Protess & Jessica Silver-Greenberg, JPMorgan Is Penalized \$2 Billion Over Madoff,N.Y. TIMES (Jan. 7, 2014, 9:37 PM), https://archive.nytimes.com/dealbook.nytimes.com/2014/01/07/jpmorgan-settles-with-federalauthorities-in-madoff-case/.
+
+<sup>&</sup>quot; 9 /d.
+
+<sup>120</sup>id.
+
+<sup>121</sup>Dawn Kopecki & Max Abelson, JPMorgan Gave Risk Oversight to Museum Head, BLOOMBERG BUSINESSWEEK (May 24, 2012), hnp://vvww.law.harvard.edu/programs/corp\_gov/MediaMentions/05-24-12\_Businessweek.pdf.
+
+<sup>122</sup> Alicia Tatone, Global Banks Defy U.S. Crackdowns by Serving Oligarchs, Criminals and Terrorists, INT'L CONSORTIUM OF INVESTIGATIVE JOURNALISTS (Sept. 20, 2020),
+
+- From 2010 through 2015, a shell company operated by Semion Mogilevich, a Russian mafia figure described as the "Boss of Bosses," sent and received more than \$1 billion in transactions through JPM. Mogilevich has been at the top of the FBI's most wanted listed since 2009.123
+- From 2012 through 2016, JPM moved more than \$63 million for companies linked to Alejandro "Piojo" Isturiz, a former Venezuelan government official who has been charged by U.S. authorities as a player in an international money laundering scheme.124
+- From 2013 through 2016, Jho Low, a financier accused by authorities in multiple countries of being the mastermind behind the embezzlement of more than \$4.5 billion from a Malaysian economic development fund called 1Malaysia Development Berhad, or I MDB, moved over \$1.2 billion through JPM.<sup>125</sup>
+- From 2016 through 2017, JPM shuttled at least \$6.9 million in transactions for Paul Manafort in the 14 months after he resigned from Donald Trump's 2016 presidential campaign amid allegations of money laundering and corruption "spawning from his work with a pro-Russian political party in Ulcraine."128
+- Even after JPM allegedly closed Epstein's accounts with the bank in 2013, a current JPM employee continued to meet with Epstein at this Manhattan townhouse until at least 2017.127
+- In December 2019, JPM faced a regulatory penalty for its KYC deficiencies. FINRA fined JPM \$200,000 for failure to supervise custodian accounts resulting in violations of KYC rules from 2014 to 2018.'28
+
+173. In addition to its AML and KYC woes, earlier this month, June 2023, the SEC fined
+
+JPM \$4 million for mistakenly deleting 47 million electronic records, including emails and instant
+
+https://www.icij.org/investigations/fincen-files/global-banks-defy-u-s-crackdowns-by-servingoligarchs-criminals-and-terrorists/.
+
+123 /d.
+
+124 /d.
+
+M.
+
+126m.
+
+<sup>127</sup> Khadeeja Safdar & David Benoit, JPMorgan's Ties to Jeffrey Epstein Were Deeper Than the Bank Has Acknowledged, WALL ST. J. (Apr. 21, 2023, 3:35 PM), https://vvww.wsj.com/articlesipmorgan-jeffrey-epM-525febe3.
+
+<sup>128</sup> FINRA, Letter of Acceptance, Waiver and Consent No. 2017053791901 (Dec. 26, 2019),
+
+messages, dated from January to April 2018, i.e., right when allegations concerning Epstein were squarely in the public eye. As a result of the deletion, the SEC stated that JPM could not come up with requested documents in eight SEC investigations and four other regulatory probes.129
+
+### VII. THE JANE DOE AND USV/ACTIONS BRING TO LIGHT JPM'S PARTICIPATION IN EPSTEIN'S CRIMES
+
+174. On November 24, 2022, the initial complaint in the Jane Doe Action was filed. That suit arose from "JP Chase Bank, N.A.'s ... participation and intentional involvement in Jeffery Epstein's widespread and well-publicized sex-trafficking operation, as well as the direct financial benefits it received therefrom."130 The complaint in the Jane Doe Action publicized, for the first time, JPM's alleged involvement in and facilitation of Epstein's crimes.
+
+175. On December 27, 2022, the initial complaint in the USVI Action was filed. That suit arose from the Attorney General of the U.S. Virgin Islands' "ongoing effort to protect public safety and to hold accountable those who facilitated or participated in, directly or indirectly, the trafficking enterprise Epstein helmed."131 According to the operative complaint in that action:
+
+> The [U.S. Virgin Islands'] investigation revealed that JP knowingly, negligently, and unlawfully provided and pulled the levers through which recruiters and victims were paid and was indispensable to the operation and concealment of the Epstein trafficking enterprise. Financial institutions can connect — or choke — human trafficking networks, and enforcement actions filed and injunctive relief obtained by attorneys general are essential to ensure that enterprises like Epstein's cannot flourish in the future.I32
+
+<sup>129</sup> Austin Weinstein, JPMorgan (JPM) Mistakenly Deleted 47 Million Records, SEC Alleges, BLOOMBERG (June 22, 2023, 10:50 AM), https://www.bloomberg.cominewearticles/2023-06- 22/jpmorgan-mistakenly-deleted-47-million-records-sec-alleges#xj4y7vzkg.
+
+<sup>130</sup>First Am. Compl. at 1, Jane Doe I Doe v. JP Chase Bank N.A., 22-cv-10019 (S.D.N.Y. 2023) (22-cv-10019).
+
+<sup>131</sup> Second Am. Compl. at 2, Government of the United States Virgin Islands v. JP Chase Bank, N.A.(S.D.N.Y. 2023) (22-cv-10904).
+
+<sup>132</sup> M
+
+176. On March 20, 2023, this Court granted in part and denied in part the motions to dismiss filed in the Jane Doe and USV/ Actions.
+
+177. On May 26, 2023, Dimon sat for a deposition in connection with the Jane Doe and USV/ Actions. During the weekend of June 10-11, 2023, Staley sat for a deposition in connection with the Jane Doe and USV/ Actions.
+
+178. The following Monday, June 12, 2023, JPM announced that it had settled the Jane Doe Action for \$290 million. <sup>133</sup> That settlement, if approved by this Court, would be one of the largest ever for a civil sex-trafficking case.' <sup>34</sup>
+
+179. The USV/ Action remains pending.
+
+## VIII. DEFENDANTS BREACHED THEIR FIDUCIARY DUTY AND HAVE CAUSED HARM TO JPM
+
+180. As fiduciaries of JPM, a Delaware corporation, Defendants' fiduciary duties required them to institute an adequate oversight system in order to ensure compliance with positive law, including federal laws (such as the BSA and Patriot Act) concerning AML. Defendants plainly did not do so.
+
+181. As discussed above in detail, JPM's compliance team repeatedly flagged that Epstein was a convicted felon, accused of running a sex trafficking ring financed primarily in cash, and withdrew and transferred huge sums of money. Executives at the highest reaches of the Company were aware of these facts. It is indisputable that Staley (who allegedly participated personally in Epstein's sex ring) and Erdoes were aware of the allegations levied against Epstein, as was Cutler, the General Counsel who vociferously advocated for JPM to sever ties with Epstein.
+
+<sup>&#</sup>x27;33 Khadeeja Safdar & David Benoit, JPMorgan to Pay \$290 Million to Settle Jeffrey Epstein Accusers' Suit, WSJ (June 12, 2023, 12:42 PM), https://www.wsj.com/articles/jpmorgan-chaseagrees-to-settle-jeffrey-epstein-accusers-suit-9dbbabff
+
+<sup>134</sup>Id.
+
+Moreover, it is inferable from the Company's own documents that Dimon personally reviewed Epstein's account in 2008 and decided to retain him as a JPM client.
+
+182. Nevertheless, the Board and Company officers never acted on this information, terminated the Company's relationship with Epstein, or filed the legally required SARs. It was a clear breach of duty for JPM fiduciaries to be willfully blind and deaf to the highly publicized allegations against Epstein, who was a prominent figure in the financial world.
+
+183. These breaches of fiduciary duty occurred at least from Epstein's 2008 guilty plea through his 2019 death, a period over which the JPM filed zero SARs related to Epstein.
+
+184. Defendants' breaches of fiduciary duty have caused massive harm to the Company. The Company already has agreed to settle the Jane Doe Action for \$290 million, and the USVJ Action remains pending. Moreover, JPM's deep and lasting affiliation with Epstein has caused incalculable reputational harm (as the Company's own filings warn is a severe risk of not complying with its regulatory obligations).
+
+# DEMAND FUTILITY ALLEGATIONS
+
+185. Plaintiffs did not make a demand on the Board to institute this Action because presuit demand is excused.
+
+186. Plaintiffs repeat and reallege each allegation above as if set forth in full in this Demand Futility Allegations section.
+
+187. Demand is excused because there exists a reasonable doubt that, at a minimum, at least half of the Board at the time that this Complaint is filed could properly exercise independent and disinterested business judgment in responding to a demand.
+
+188. The demand Board has 12 members: Bammann, =, Combs, Crown, Dimon, Flynn, Alex Gorsky ("Gorsky"), Hobson, Michael A. Neal ("Neal"), Novakovic, and Rometty. Demand is therefore futile if at least six of the 12 directors either lack independence,
+
+are not disinterested, or both. Here, at least nine directors lack independence, are not disinterested, or both: Bammann, M, Combs, Crown, Dimon, Flynn, Hobson, Neal, and Novakovic.
+
+189. Bammann, Combs, Crown, Dimon, Flynn, Hobson, and Neal are not disinterested because they face a substantial likelihood of liability, whether in this Action, the USV/ Action or in the Jane Doe Action. Each of these directors have served on the Board at times between Epstein's 2008 plea and his 2019 death. Yet, the Company plainly failed to comply with positive law, as evidenced by the fact that the Board never discussed JPM's relationship with Epstein and the Company did not file a single SAR related to Epstein over this timeframe.
+
+190. Bammann, Crown, Dimon, , and Flynn face an even more heightened likelihood of liability, given that they all served on the Board before the Company purportedly terminated its relationship with Epstein in 2013.
+
+191. Moreover, and separately, Dimon faces a substantial likelihood of liability because it appears that he knew about JPM's relationship with Epstein as of at least 2008 (if not earlier, during his days in Columbus, Ohio and at Bank One) and knew about Epstein's guilty plea, yet Dimon failed to cause the Company to terminate its relationship with Epstein, failed to address Epstein with the Board, and failed to cause the Company to file a single SAR concerning Epstein.
+
+192. Additionally, Bammann, Crown, and Novakovic are not independent from Dimon and/or Crown.
+
+193. Bammann owes a significant portion of her professional success to Dimon. While Dimon was the CEO of Bank One, Bammann reached the status of Bank One's Executive Vice President and Chief Risk Management Officer from 2001 to 2004. Then, after JPM acquired Bank One, when Dimon was JPM's President and Chief Operating Officer, Bammann served as the Company's Deputy Head of Risk Management. Moreover, the Board invited Bammann to join 2013, while Dimon attained his current roles of CEO and Chairman. Bammann's only employment since 2013 has been her role as a JPM director.
+
+194. Crown served on the board of directors of Bank One from 1991 until its sale to JPM in 2004, and Crown was one of the people who selected Dimon to be Bank One's CEO in 2000. Crown also advocated for Dimon to assume a leadership role at JPM. Moreover, Crown was involved in the New Albany project, which relied on Epstein for its success.
+
+195. Novakovic, in turn, is not independent from Crown. Novakovic is the Chairman and CEO of General Dynamics, Crown's family business. Thus, Crown likely had the influence to fire Novakovic, and it is not plausible that Novakovic would be willing to bring litigation against Crown concerning the allegations of this Complaint.
+
+# PLAINTIFFS' CLAIMS ARE TIMELY
+
+196. Plaintiffs did not know, and could not have known, that Epstein used JPM to facilitate his trafficking enterprise or that the Company turned a blind eye to unusual cash transactions and wires and failed to carry out or follow up on basic due diligence and to timely comply with federal banking regulations until the filing of the complaint in the Jane Doe Action on November 24, 2022.
+
+197. To the extent the statute of limitations even began to run before November 24, 2022, any perceived delay in Plaintiffs' filing of this Action arises due to the Board's and Company management's concerted and long-running efforts to conceal critical facts necessary to put Plaintiffs on notice of the specific facts showing the Board's and Company management's sustained and systemic breaches of fiduciary duty.
+
+198. As discussed above, despite knowing Epstein was a felon convicted for sexual abuse, a pedophile who allegedly trafficked young girls from all over the world (including on his private plane), and wired and withdrew large sums of cash from his JPM accounts, the Company
+
+failed to file a single SAR concerning Epstein and his accounts. Additionally, JPM employees including those at the highest reaches of the Company, such as Dimon, Staley, and/or Erdoes actively concealed concerns about Epstein and failed to report them to the Board and/or timely fire Epstein as a client.
+
+199. Moreover, JPM continues to try to avoid accountability for its role in Epstein's sextrafficking ring. Dimon even repeatedly denied knowing who Epstein was until 2018 or 2019, which appears to be false given the allegations above. Instead, JPM has tried to lay all blame exclusively on Staley, and the Company has asserted claims against him — but not against other executives still at the Company and who clearly had knowledge of Epstein's crimes.
+
+## CLAIMS FOR RELIEF
+
+### COUNT I Breach of Fiduciary Duty (Against the Director Defendants)
+
+200. Plaintiffs reallege the preceding paragraphs as set forth above and incorporate them herein by reference.
+
+201. The Director Defendants, as directors of JPM, were and/or are fiduciaries of the Company and its stockholders. As such, the Director Defendants owed and owe the Company and its stockholders the highest duties of good faith, due care, loyalty and candor.
+
+202. The Company was and is subject to numerous AML laws and KYC regulations. The Director Defendants' fiduciary duties oblige them to put systems in place to manage risk and ensure compliance with these laws.
+
+203. The Director Defendants, consistent with their fiduciary duties, were required to implement and maintain effective controls to ensure the Company's compliance with AML laws and KYC regulations.
+
+204. The Director Defendants consciously breached their fiduciary duties and violated their corporate responsibilities to ensure the Company's compliance with the applicable laws even when Epstein's criminal activity and criminal use of his JPM accounts and funds put them on notice, either by ignoring red flags related to Epstein's actions and failing to adhere to their own internal controls or by knowingly disregarding their own internal controls and intentionally allowing the Company to continue facilitating Epstein's criminal conduct.
+
+205. As a result of the Director Defendants' conscious failure to perform their fiduciary duties and exercise their oversight responsibilities, the Company has sustained significant damages, both financial and reputational. Such damages include, and will include, damage awards, settlements, expenses, penalties, fines, increased regulatory scrutiny, and other liabilities described herein.
+
+206. The Director Defendants' continuing decision not to correct this failure exposes the Company to comparable and continuing risks of damages in the future.
+
+207. As a result of the bad faith misconduct alleged herein, the Director Defendants are liable to the Company.
+
+### COUNT II Breach of Fiduciary Duty (Against the Officer Defendants)
+
+208. Plaintiffs reallege the preceding paragraphs as set forth above and incorporate them herein by reference.
+
+209. The Officer Defendants, as officers of JPM, were and/or are fiduciaries of the Company and its stockholders. As such, the Officer Defendants owed and owe the Company and its stockholders the highest duties of good faith, due care, loyalty and candor.
+
+210. The Company was and is subject to numerous AML laws and KYC regulations. The Officer Defendants' fiduciary duties oblige them to put systems in place to manage risk and ensure compliance with these laws.
+
+211. The Officer Defendants, consistent with their fiduciary duties, were required to implement and maintain effective controls to ensure the Company's compliance with AML laws and KYC regulations.
+
+212. The Officer Defendants consciously breached their fiduciary duties and violated their corporate responsibilities to ensure the Company's compliance with the applicable laws even when Epstein's criminal activity and criminal use of his JPM accounts and funds put them on notice, either by ignoring red flags related to Epstein's actions and failing to adhere to their own internal controls or by knowingly disregarding their own internal controls and intentionally allowing the Company to continue facilitating Epstein's criminal conduct.
+
+213. As a result of the Officer Defendants' conscious failure to perform their fiduciary duties and exercise their oversight responsibilities, the Company has sustained significant damages, both financial and reputational. Such damages include, and will include, damage awards, settlements, expenses, penalties, fines, increased regulatory scrutiny, and other liabilities described herein.
+
+214. The Officer Defendants' continuing decision not to correct this failure exposes the Company to comparable and continuing risks of damages in the future.
+
+215. As a result of the bad faith misconduct alleged herein, the Officer Defendants are liable to the Company.
+
+#### COUNT III Unjust Enrichment (Against the Individual Defendants)
+
+216. Plaintiffs re-allege the preceding paragraphs as set forth above and incorporate them herein by reference.
+
+217. As a result of the conduct described herein, the Individual Defendants breached their fiduciary duties to the Company and its stockholders. The Individual Defendants were in a position to benefit from their misconduct in the form of profits, benefits, and other compensation.
+
+218. The Individual Defendants have been unjustly enriched at the expense and to the detriment of Plaintiffs and the Company.
+
+219. It would be unconscionable and against fundamental principles of justice, equity, and good conscience for the Individual Defendants to retain the benefits that they received only by virtue of breaching their fiduciary duties.
+
+220. All profits, benefits, and other compensation that accrued to the Individual Defendants, collectively or individually, as a result of their misconduct should be disgorged.
+
+### RELIEF REQUESTED
+
+WHEREFORE, Plaintiffs, on behalf of the Company, request judgment as follows:
+
+- A. Declaring that this Action is a proper derivative action maintainable under the law and that Plaintiffs are proper and adequate representatives of the Company;
+  - B. Declaring that demand on the JPM Board is excused as futile;
+- C. Finding the Director Defendants and Officer Defendants liable for breaching their fiduciary duties owed to the Company;
+- D. Awarding damages sustained by the Company as a result of the breaches of fiduciary duty set forth above, together with pre- and post-judgment interest, from each of the Individual Defendants, jointly and severally;
+
+E. Directing JPM to take all necessary actions to reform and improve its compliance procedures and governance policies to comply with applicable laws and to protect the Company and its stockholders from a repeat of the damaging events described herein;
+
+F. Ordering immediate disgorgement of all profits, benefits, and other compensation obtained by the Individual Defendants as a result of their breaches of fiduciary duty and unjust enrichment;
+
+G. Awarding Plaintiffs' costs and expenses incurred in this Action, including, but not limited to, reasonable attorneys' fees, accountants' fees, consultants' fees, experts' fees, and costs and expenses; and
+
+221. Granting such other and further relief as the Court deems just and proper.
+
+#### JURY DEMAND
+
+Plaintiffs demand a trial by jury on all claims so triable.
+
+Date: June 30, 2023
+
+BERNSTEIN LITOWITZ BERGER & GROSSMANN LLP
+
+Daniel Meyer 500 Delaware Avenue, Suite 901 Wilmington, DE 19801 (302) 364-3600
+
+Respectfully submitted,
+
+BERNSTEIN LITOWITZ BERGER & GROSSMANN LLP
+
+Isl Mark Lebovitch
+
+Mark Lebovitch Sara Swartzwelder 1251 Avenue of the Americas New York, New York 10020 (212) 554-1400
+
+Counsel for Plaintiff City of Miami General Employees & Sanitation Employees Retirement Trust
+
+#### GRANT & EISENHOFER P.A.
+
+Isl Rebecca A. Musarra
+
+Rebecca A. Musarra
+
+J. Orrico
+
+Vivek Upadhya
+
+485 Lexington Ave., 29th Floor
+
+New York, New York 10017
+
+rmusarra@gelaw.com
+
+corrico@gelaw.com
+
+vupadhya@gelaw.com
+
+(646) 722-8500
+
+Michael J. Barry (admitted pro hac vice)
+
+Christine M. Mackintosh (admitted pro hac vice)
+
+123 Justison St.
+
+Wilmington, DE 19801
+
+mbarry@gelaw.com
+
+cmackintosh®gelaw.com
+
+(302) 622-7000
+
+Counsel for Plaintiff Operating Engineers
+
+Construction Industry and Miscellaneous Pension Fund
+
+![](_page_67_Picture_1.jpeg)
+
+#### VERIFICATION
+
+I, Edgard Ma Administrator for the City of Miami General Employees' & Sanitation Employees' Retirement Trust (the "Trust"), hereby verify that the Trust currently holds JPMorgan Chase & Co. (the "Company") common and has held such stocks at all legally required times pertinent to this action. The Trust is ready, willing, and able to pursue this stockholder derivative action on behalf of and for the benefit of the Company.
+
+<sup>I</sup>have reviewed the allegations in the attached Verified Amended Stockholder Derivative Complaint, and as to those allegations of which I have personal knowledge, I know those allegations to be true, accurate, and complete. As to those allegations of which I do not have personal knowledge, I rely on my counsel and their investigation, and for that reason I believe them to be true. Having received and reviewed a copy of the Verified Amended Stockholder Derivative Complaint, and having reviewed it with my counsel, 1 hereby authorize its filing.
+
+<sup>I</sup>declare under penalty of perjury that the foregoing is true and correct.
+
+Executed on this 30 day of June, 2023.
+
+Edg•r. andez, Pension Administrator
+
+#### VERIFICATION
+
+I, M. Scott . Trustee for the Operating Engineers Construction Industry and Miscellaneous Pension Fund (the "Operating Engineers"), hereby verify that the Operating Engineers have held in JPMorgan Chase & Co. at all relevant times herein. The Operating Engineers are ready, willing, and able to pursue this stockholder derivative action on behalf of and for the benefit of JP . I have reviewed the allegations in the attached Verified Amended Stockholder Derivative Complaint, and as to those allegations of which I have personal knowledge, I know those allegations to be true, accurate, and complete. As to those allegations of which I do not have personal knowledge, I rely on my counsel and their investigation, and for that reason I believe them to be true. Having received a copy of the Verified Amended Stockholder Derivative Complaint, and having reviewed it with my counsel. I hereby authorize its filing.
+
+I declare under penalty of perjury that the foregoing is true and correct.
+
+Executed on:
+
+June 3(0. 2023
+
+M. Scott-, Administrator Operating Engineers Construction Industry and Miscellaneous Pension Fund
\ No newline at end of file
diff --git a/marker2/court-pension-v-dimon/EFTA02822837/EFTA02822837.metadata.json b/marker2/court-pension-v-dimon/EFTA02822837/EFTA02822837.metadata.json
new file mode 100644
index 0000000000000000000000000000000000000000..21962ec722ae0ef38cf5de83858b769e00f784f8
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+        "title": "UNITED STATES DISTRICT COURT FOR THE \nSOUTHERN DISTRICT OF NEW YORK",
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+      {
+        "title": "PARTIES AND RELEVANT NON-PARTIES",
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+        "title": "C. Director Defendants",
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+        "title": "I. COMPLIANCE WITH BANKING LAWS AND REGULATIONS IS MISSION-\nCRITICAL TO JPM'S BUSINESS",
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+        "title": "V. EPSTEIN REMAINS A JPM CLIENT WHILE THE TRUTH ABOUT HIM COMES \nINTO THE PUBLIC EYE",
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+        "title": "VII. THE JANE DOE AND USV/ACTIONS BRING TO LIGHT JPM'S PARTICIPATION \nIN EPSTEIN'S CRIMES",
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+        "title": "VIII. DEFENDANTS BREACHED THEIR FIDUCIARY DUTY AND HAVE CAUSED \nHARM TO JPM",
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+        "title": "DEMAND FUTILITY ALLEGATIONS",
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+        "title": "PLAINTIFFS' CLAIMS ARE TIMELY",
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+## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E. STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+Defendants,
+
+and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+Case No. 1:23-cv-03903-JSR
+
+## STIPULATION AND [PROPOSED] ORDER OF DISMISSAL OF CERTAIN DEFENDANTS WITHOUT PREJUDICE
+
+WHEREAS, Plaintiff's Verified Stockholder Derivative Complaint (the "Complaint"), filed on May 9, 2023, asserts claims against Defendants Ashley Bacon, Mary Erdoes, John J. Hogan, and Barry Zubrow (collectively, the "Dismissed Officer Defendants") for breach of fiduciary duty (Counts 11 and Ill); and
+
+WHEREAS, the undersigned parties have agreed to dismissal of the Dismissed Officer Defendants from the above-captioned litigation (the "Action") pursuant to the agreement outlined below.
+
+IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned parties, that:
+
+- I. The Dismissed Officer Defendants are dismissed from this Action in their entirety and without prejudice pursuant to Rule 41(a)(1) of the Federal Rules of Civil Procedure;
+- 2. The Dismissed Officer Defendants will submit, without waiver herein of any objections, including objections to duplicative discovery, to discovery under the Federal Rules of Civil Procedure and Local Rules (including Federal Rules 26, 33, 34, and 36) as though the Dismissed Officer Defendants were parties to the Action, including document and deposition discovery;
+- 3. In accordance with and to the extent required by the Federal Rules of Civil Procedure, and without waiver of any objections, the Dismissed Officer Defendants will make themselves available for any trial, hearing, or other Court proceeding at which Plaintiff determines in good faith that the live testimony of the Dismissed Officer Defendants is necessary;
+- 4. The Dismissed Officer Defendants agree to toll any limitations period applicable to the claims asserted against them in Count II and Count III of the Complaint, with such tolling running from the date of entry of this stipulation until November 30, 2023, unless extended by mutual agreement of all Parties; and
+
+- 5. The Court retains jurisdiction over the implementation and enforcement of the terms of this Stipulation and any disputes arising from or relating thereto.
+
+## Dated: June 30, 2023 GRANT & EISENHOFER P.A.
+
+/s/ Rebecca A. Musarra
+
+Rebecca A. Musarra
+
+J. Orrico
+
+Vivek Upadhya 485 Lexington Ave., 29th Floor New York, NY 10017 rmusarra@gelaw.com corrico@gelaw.com vupadhya@gelaw.com (646) 722-8500
+
+Michael J. Barry (admitted pro hac) Christine M. Mackintosh (admitted pro hac) 123 Justison St. Wilmington DE 19801 mbarry@gelaw.com cmackintosh@gelaw.com (302) 622-7000
+
+Counsel for Plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund
+
+Is/ Timothy Perla
+
+## WILMER CUTLER PICKERING HALE AND DORR LLP
+
+Timothy Perla 60 State Street Boston, 02109 (t) (617) 526-6000 (f) (617) 526-5000 timothy.perla@wilmerhale.com
+
+Noah A. Levine 7 World Trade Center 250 Greenwich Street New York, NY 10007 (t) (212) 230-8800
+
+(f) (212) 230-8888
+
+noah.levine@wilmerhale.com
+
+Counsel for Defendants Ashley Bacon, Mary C. Erdoes, John J. Hogan, Barry L. Zubrow
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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL. JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. NM, TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E. STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+Defendants,
+
+and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+Case Number: 1:23-cv-03903-JSR
+
+AFFIDAVIT OF JOHN MCNICHOLS IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE
+
+## DECLARATION OF JOHN MCNICHOLS
+
+I, John McNichols, do declare as follows:
+
+- 1. I am a partner at & Connolly LLP, 680 Maine Avenue S.W., Washington, D.C. 20024.
+- 2. I am a member in good standing of the bars of Maryland, Virginia, and the District of Columbia.
+
+1. 3. I have never been convicted of a felony.
+2. 4. I have never been censured, suspended, disbarred, or denied admission or readmission by any court.
+3. 5. There are no pending disciplinary proceedings against me in any state or federal court.
+
+I declare under penalty of perjury that the foregoing is true and correct.
+
+Dated: June 27, 2023
+
+![]()Subscribed and sworn to before me
+
+This 27 day of June 2023
+
+![]()My Commission Expires 8.31.2024
+
+SHARON L. BROWN  
+NOTARY PUBLIC DISTRICT OF COLUMBIA  
+My Commission Expires August 31, 2024
+
+![](_page_1_Picture_82.jpeg)
\ No newline at end of file
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+![](_page_0_Picture_1.jpeg)
+
+![](_page_0_Picture_2.jpeg)
+
+On behalf of JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals, the District of Columbia Bar does hereby certify that
+
+## John M Mcnichols
+
+was duly qualified and admitted on January 10, 2005 as an attorney and counselor entitled to practice before this Court; and is, on the date indicated below, an Active member in good standing of this Bar.
+
+![](_page_0_Picture_6.jpeg)
+
+For questions or concerns, please contact the D.C. Bar Membership Office at 202-626-3475 or email memberservices@dcbar.org.
+
+Issued By:
+
+David . Director. Membership District of Columbia Bar Membership
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+# Supreme Court of Maryland
+
+Annapolis, MD
+
+![](_page_0_Picture_74.jpeg)
+
+## *CERTIFICATE OF GOOD STANDING*
+
+STATE OF MARYLAND, ss:
+
+I, Gregory Hilton, Clerk of the Supreme Court of Maryland, do hereby certify that on the twenty-second day of March, 2012,
+
+***John Marcus McNichols***
+
+having first taken and subscribed the oath prescribed by the Constitution and Laws of this State, was admitted as an attorney of said Court, is now in good standing, and as such is entitled to practice law in any of the Courts of said State, subject to the Rules of Court. This certificate of good standing is valid through the twenty-sixth day of August, 2023.
+
+![](_page_0_Picture_80.jpeg)
+
+**In Testimony Whereof,** I have hereunto set my hand as Clerk, and affixed the Seal of the Supreme Court of Maryland, this twenty-seventh day of June, 2023.
+
+![]()
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+## iipupreme Court of 'Virginia
+
+AT RICHMOND
+
+## Certificate
+
+I, Muriel-Theresa Pitney, Clerk of the Supreme Court of Virginia, do hereby certify that
+
+John Marcus McNichols
+
+was admitted to practice as an attorney and counsellor at the bar of this Court on June 7, 2004.
+
+I further certify that so far as the records of this office are concerned, John Marcus McNichols is a member of the bar of this Court in good standing.
+
+Witneso my hand and seal of said Court
+
+This 29th day of June
+
+A.D. 2023
+
+By: A-M, eputy Clerk
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diff --git a/marker2/court-pension-v-dimon/EFTA02822915/EFTA02822915.md b/marker2/court-pension-v-dimon/EFTA02822915/EFTA02822915.md
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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND.
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS. CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP. RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E. STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+Defendants,
+
+and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+Case Number: 1:23-cv-03903-JSR
+
+[PROPOSED] ORDER GRANTING MOTION FOR ADMISSION PRO HAC VICE
+
+The motion of John McNichols for admission to practice pro hac vice in the abovecaptioned action is GRANTED. Applicant has declared that he is a member in good standing of the bars of the District of Columbia, Virginia, and Maryland and that his contact information is as follows:
+
+Applicant's Name: John McNichols
+
+Finn Name: & Connolly LLP
+
+Address: 680 Maine Avenue, S.W.
+
+City/State/Zip: Washington, D.C. 20024
+
+Telephone/Fax: (202) 434-5043 / (202) 434-5029
+
+Email: JMcnichols@wc.com
+
+Applicant having requested admission pro hac vice to appear for all purposes as counsel for Defendant James Edward Staley in the above-captioned action;
+
+IT IS HEREBY ORDERED that Applicant John McNichols is admitted to practice pro hac vice in the above-captioned action in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys.
+
+Dated:
+
+Honorable Jed S. Rakoff United States District Judge
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02822917/EFTA02822917.md b/marker2/court-pension-v-dimon/EFTA02822917/EFTA02822917.md
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@@ -0,0 +1,41 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND.
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA B. BAMMANN, JAMES A. BELL, JOHN H. BIGGS, CRANDALL C. BOWLES, STEPHEN B. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E. STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+Defendants, and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+Case Number: 1:23-cv-03903-JSR
+
+## MOTION FOR ADMISSION PRO HAC VICE FOR JOHN MCNICHOLS
+
+Pursuant to Rule 1.3(c) of the Local Rules for the United States District Courts for the Southern and Eastern Districts of New York, I, John McNichols, hereby move this Court for an Order for admission to practice pro hoc vice to appear as counsel in the above-captioned case on behalf of Defendant James Edward Staley.
+
+I am a member in good standing of the bars of Virginia, Marlyand and the District of Columbia, and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony.
+
+I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3.
+
+Dated: June 30, 2023 Respectfully submitted,
+
+/s/ John McNichols
+
+Applicant Signature
+
+Applicant's Name: John McNichols Firm name: & Connolly LLP Address: 680 Maine Avenue, S.W. City / State / Zip: Washington, D.C. 20024 Telephone: (202) 434-5043 Fax: (202) 434-5029 Email: JMcnichols@wc.com
+
+Attorney for James Edward Staley
+
+## CERTIFICATE OF SERVICE
+
+I hereby certify that on June 30,2023, I electronically filed the foregoing document with the Clerk of Court using the CM/ECF system which will send notification of such filing to all counsel of record in this matter who are on the CM/ECF system.
+
+> /s/ John McNichols John McNichols
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02822920/EFTA02822920.md b/marker2/court-pension-v-dimon/EFTA02822920/EFTA02822920.md
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+## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JPMORGAN CHASE & CO. DERIVATIVE LITIGATION
+
+Case No. I :23-cv-03903-JSR DERIVATIVE ACTION
+
+## NOTICE OF APPEARANCE
+
+PLEASE TAKE NOTICE THAT the undersigned, of the law farm of Paul, Weiss, Rifkind, Wharton & Garrison LLP, is hereby entering an appearance as counsel of record for Phebe N. Novakovic.
+
+Dated: July 6, 2023
+
+New York, NY Respectfully submitted,
+
+PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
+
+By: /s/ Jessica S. Carey Jessica S. Carey
+
+1285 Avenue of the Americas New York, NY 10019 Tel: (212) 373-3000 Fax: (212) 757-3990 jcarey@paulweiss.com
+
+Counsel for Defendants Stephen'. Todd A. Combs, James S. Crown, Timothy P. Flynn, Mellody Hobson, John W. Kessler, and Phebe N. Novakovic.
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02822921/EFTA02822921.md b/marker2/court-pension-v-dimon/EFTA02822921/EFTA02822921.md
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+## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JPMORGAN CHASE & CO. DERIVATIVE LITIGATION
+
+Case No. I :23-cv-03903-JSR DERIVATIVE ACTION
+
+## NOTICE OF APPEARANCE
+
+PLEASE TAKE NOTICE THAT the undersigned, of the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP, is hereby entering an appearance as counsel of record for Phebe N. Novakovic.
+
+Dated: July 6, 2023
+
+New York, NY Respectfully submitted,
+
+PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
+
+By: /s/Audra J. Soloway Audra J. Soloway
+
+1285 Avenue of the Americas New York, NY 10019 Tel: (212) 373-3000 Fax: (212) 757-3990 asoloway@paulweiss.com
+
+Counsel for Defendants Stephen'. Todd A. Combs, James S. Crown, Timothy P. Flynn, Mellody Hobson, John W. Kessler, and Phebe N. Novakovic.
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02822922/EFTA02822922.md b/marker2/court-pension-v-dimon/EFTA02822922/EFTA02822922.md
new file mode 100644
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@@ -0,0 +1,21 @@
+## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JPMORGAN CHASE & CO. DERIVATIVE LITIGATION
+
+Case No. I :23-cv-03903-JSR DERIVATIVE ACTION
+
+## NOTICE OF APPEARANCE
+
+PLEASE TAKE NOTICE THAT the undersigned, of the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP, is hereby entering an appearance as counsel of record for Phebe N. Novakovic.
+
+Dated: July 6, 2023
+
+New York, NY Respectfully submitted,
+
+PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
+
+By: /s/ Jacobus J. Schutte Jacobus J. Schutte
+
+1285 Avenue of the Americas New York, NY 10019 Tel: (212) 373-3000 Fax: (212) 757-3990 jschutte@paulweiss.com
+
+Counsel for Defendants Stephen'. Todd A. Combs, James S. Crown, Timothy P. Flynn, Mellody Hobson, John W. Kessler, and Phebe N. Novakovic.
\ No newline at end of file
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+Case No. 1:23-CV-03903 (JSR)
+
+DERIVATIVE ACTION
+
+## SUGGESTION OF DEATH
+
+Counsel for undersigned defendants suggests upon the record, pursuant to Federal Rule of Civil Procedure 25(aX1), the death of defendant JAMES S. CROWN on June 25, 2023, during the pendency of this action.
+
+Dated: July 6, 2023 New York, NY
+
+cc: Counsel of Record (Via ECF)
+
+Respectfully submitted,
+
+PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
+
+By: /s/ Jacobus J. Schutte Jacobus J. Schutte Jessica S. Carey Audra J. Soloway 1285 Avenue of the Americas New York, NY 10019 Tel: (212) 373-3000 Fax: (212) 757-3990 jschutte@paulweiss.com
+
+Counsel for Defendants Stephen..=, Todd A. Combs, James S. Crown, Timothy P. Flynn, Mellody Hobson, John W. Kessler, and Phebe N. Novakovic.
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+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+Case No. 1:23-CV-03903 (JSR)
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+# DERIVATIVE ACTION
+
+# NOTICE OF MOTION TO DISMISS THE AMENDED STOCKHOLDER DERIVATIVE COMPLAINT
+
+PLEASE TAKE NOTICE THAT, upon the accompanying memorandum of law, the declaration of Audra. J. Soloway and the exhibits annexed thereto, and all other papers and proceedings herein, Defendants JPMorgan Chase & Co., Stephen , Todd Combs, James Crown, Timothy Flynn, Mellody Hobson, John Kessler, Phebe Novakovic and James Dimon, by and through their attorneys, hereby respectfully move this Court, before the Honorable Jed S. Rakoff, United States District Judge, United States District Court for the Southern District of New York, Daniel Moynihan Courthouse, 500 Pearl Street, Courtroom 14B, New York, New York 10007, for an order, pursuant to Federal Rules of Civil Procedure 23.1 and 12(bX6), dismissing Plaintiffs' Amended Stockholder Derivative Complaint (ECF No. 17) on a date and time to be set by the Court. The grounds for this motion are set forth in the accompanying memorandum of law.
+
+Dated: July 6, 2023 New York, New York
+
+## WILMER CUTLER PICKERING HALE AND DORR LLP
+
+By: /s/ Timothy Perla Timothy Perla 60 State Street Boston, 02109 (t) (617) 526-6000 (f) (617) 526-5000 timothy.perla®wilmerhale.com
+
+Noah A. Levine 7 World Trade Center 250 Greenwich Street New York, NY 10007 (t) (212) 230-8800 (t) (212) 230-8888 noah.levine@wilmerhale.com
+
+## PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
+
+By: /s/Audra J. Soloway Audra J. Soloway Jessica S. Carey Jacobus J. Schutt 1285 Avenue of the Americas New York, NY 10019-6064 Phone: (212) 373-3000 Fax: (212) 757-3990 asoloway@paulweiss.com
+
+Counsel for Director Defendants Stephen B. , Todd A. Combs, James S. Crown, Timothy P. Flynn, Mellody Hobson, John W. Kessler, and Phebe N. Novakovic
+
+Counsel for Defendants JPMorgan Chase & Co. and James Dimon
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@@ -0,0 +1,360 @@
+# UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+M Case No. 1:23-CV-03903 (JSR)
+
+DERIVATIVE ACTION
+
+# MEMORANDUM OF LAW IN SUPPORT OF DEFENDANTS' MOTION TO DISMISS
+
+### TABLE OF CONTENTS
+
+|                             | Page                                                                                                         |
+|-----------------------------|--------------------------------------------------------------------------------------------------------------|
+| Table of Authorities H. HI. | ii                                                                                                           |
+| A.                          | Legal Standard for Demand Futility ........................................................................9 |
+| B.                          | Plaintiffs Fail to Plead Particularized Facts Demonstrating that a Majority                                  |
+|                             | I. Eight Demand Board members assumed membership on the                                                      |
+|                             | client. I I                                                                                                  |
+|                             | 2. Plaintiffs fail to plead particularized facts demonstrating that the                                      |
+|                             | 3. Plaintiffs fail to plead particularized facts demonstrating the                                           |
+| C. IV.                      | Plaintiffs Fail to Plead Particularized Facts Demonstrating That Any                                         |
+| A.                          | Legal Standard Under Rule 12(bX6).....................................................................18     |
+| B.                          | The Complaint Fails to State a Fiduciary Duty Claim Against Any                                              |
+| C.                          | The Complaint Fails to State a Fiduciary Duty Claim Against Mr. Dimon ..........20                           |
+| D.                          | The Complaint Fails to State a Claim for Unjust Enrichment...............................24                  |
+| V.                          | Conclusion 25                                                                                                |
+
+# TABLE OF AUTHORITIES
+
+| Cases In re Am. Intl Grp., Inc. Derivative Litig.,                                                                | Page(s)   |
+|-------------------------------------------------------------------------------------------------------------------|-----------|
+| 700 F. Supp. 2d. 419 (S.D.N.Y. 2010), afd, 415 F. App'x 285 (2d Cir. 2011) Aronson v. M,                          | 10        |
+| 473 A.2d 805 (Del. 1984) Ashcroft v. lqbal,                                                                       | 10        |
+| 556 U.S. 662 (2009) Cantor Fitzgerald, L.P. v. Cantor,                                                            | 18        |
+| 724 A.2d 571 (Del. Ch. 1998) In re Caremark Intl Inc. Derivative Litig.,                                          | 24        |
+| 698 A.2d 959 (Del. Ch. 1996)                                                                                      | 3, II, 19 |
+| Caspian Select Credit Fund Ltd. v. Gohl,                                                                          |           |
+| No. CV 10244-VCN, 2015 WL 5718592 (Del. Ch. Sep. 28, 2015) In re Citigroup Inc. S'holder Derivative Litig.,       | 25        |
+| 964 A.2d 106 (Del. Ch. 2009) Constr. Indus. Laborers Pension Fund v. Bingle,                                      | 9, 14     |
+| 411, 2022, 2023 WL 3513271 (Del. May 17, 2023) Corp. Risk Holdings LLC v. Rowlands,                               | 11, 19    |
+| No. 17-CV-5225 (RJS), 2018 WL 9517195 (S.D.N.Y. Sept. 28, 2018) David B. Shaev Profit Sharing Acct. v. Armstrong, | 15        |
+| A.2d 802 (Del. 2006) In re Delta and Pine Land Co. S'holders Litig.,                                              | 14        |
+| No. Civ.A. 17707, 2000 WL 875421 (Del. Ch. June 21, 2000) Desimone v. Barrows,                                    | 10        |
+| 924 A.2d 908 (Del. Ch. 2007) Firemen's Ret. Sys. of St. Louis v. Sorenson,                                        | 11        |
+| No. CV 2019-0965-LWW, 2021 WL 4593777 (Del. Ch. Oct. 5, 2021)                                                     | 13        |
+
+# TABLE OF AUTHORITIES
+
+(Continued)
+
+|                                                                                               | Page(s) |
+|-----------------------------------------------------------------------------------------------|---------|
+| 4452338 (Del. Ch. Sept. 29, 2021)                                                             | 23      |
+| 23-cv-10904 (S.D.N.Y. 2023) Guttman v. Huang,                                                 | 4, 25   |
+| 823 A.2d 492 (Del. Ch. 2003) Harcum v. Lovoi,                                                 | 15      |
+| C.A. No. 2020-0398-PAF, 2022 WL 29695 (Del. Ch. Jan. 3, 2022) /Forman v. Abney,               | 24      |
+| No. CV 12290-VCS, 2017 WL 242571 (Del. Ch. Jan. 19, 2017) In re 177' Corp. Derivative Litig., | 23      |
+| 588 F. Supp. 2d 502 (S.D.N.Y. 2008) Jane Doe I v. JPMorgan Chase Bank, N.A.,                  | 15      |
+| 22-cv-10019 (JSR) (S.D.N.Y. 2022) Kahn v. M & F Worldwide Corp.,                              | 4, 25   |
+| Intl, Inc., 195 A.3d 754 (Del. 2018) Kococinski v.                                            | 17      |
+| 935 F. Supp. 2d 909 (D. Minn. 2013) (D. Minn. 2013) Kravitz v. Tavlarios,                     | 10      |
+| No. 20-2579-CV, 2021 WL 5365582 (2d Cir. Nov. 18, 2021)                                       | 15      |
+| No. 20 CIV. 3773 (LGS), 2021 WL 2037552 (S.D.N.Y. May 21, 2021)                               | 25      |
+| 845 A.2d 1040 (Del. 2004)                                                                     | 17      |
+| 289 A.3d 343 (Del. Ch. 2023)                                                                  | 20, 21  |
+| In re Merrill & Co., Inc., Sec., Derivative & ERISA Litig.,                                   |         |
+| 773 F. Supp. 2d 330 (S.D.N.Y. 2011) (JSR)                                                     | 12      |
+
+# TABLE OF AUTHORITIES
+
+(Continued)
+
+Page(s)
+
+Meyers v. Keeler, 414 F. Supp. 935 (W.D. Olda. 1976) 11
+
+In re Stanley Derivative Litig., 542 F. Supp. 2d 317 (S.D.N.Y. 2008) 17
+
+Okla. Firefighters Pension & Ret. Sys. v. Corbat, No. CV 12151-VCG, 2017 WL 6452240 (Del. Ch. Dec. 18, 2017) 13
+
+In re: Old Bpsush, Inc., No. 16-12373 (BLS), 2021 WL 4453595 (D. Del. Sept. 29, 2021) 23
+
+Pettry v. M, C.A. No. 2019-0795-JRS, 2021 WL 2644475 (Del. Ch. Jun. 28, 2021) 14, 20
+
+In re Pfizer Inc. S'holder Derivative Litig., 722 F. Supp. 2d 453 (S.D.N.Y. 2010) 24
+
+Rahbari v. Oros, 732 F. Supp. 2d 367 (S.D.N.Y. 2010) 18
+
+Rales v. Blasband, 634 A.2d 927 (Del. 1993) 9
+
+Ret. Sys. v. Roche, 2020 WL 7023896 (Del. Ch. Nov. 30, 2020) 24
+
+v. Ellison, C.A. No. 2018-0755-AGB, 2019 WL 3408812 (Del. Ch. Jul. 29, 2019) 16
+
+In re SAIC Derivative Litig., 948 F. Supp. 2d 366 (S.D.N.Y. 2013) 14
+
+Scalisi v. Fund Asset Mgmt., L.P., 380 F.3d 133 (2d Cir. 2004) 9
+
+South v. Baker, 62 A.3d 1 (Del. Ch. 2012) 14, 16
+
+Steinberg v. Dimon, No. 14 Civ. 688 (PAC), 2014 WL 3512848 (S.D.N.Y. July 16, 2014) 15
+
+## TABLE OF AUTHORITIES (Continued)
+
+| v. Ritter,                                                                      | Page(s)  |
+|---------------------------------------------------------------------------------|----------|
+| 911 A.2d 362 (Del. 2006)                                                        | 11, 15   |
+| 119 A.3d 44 (Del. Ch. 2015) Tri-State Pension Fund v. Zuckerberg,               | 17       |
+| 262 A.3d 1034 (Del. 2021)                                                       | 2, 9, 16 |
+| 250 A.3d 862 (Del. Ch. 2020), aff'd sub nom. Zuckerberg, 262 A.3d 1034 Statutes | 12       |
+| D.G.C.L. § 102(bX7) Other Authorities Dies at 70, N.Y. Times (July 3, 2023),    | 10       |
+| nytimes.com/2023/06/27/business/james-crown-dead.html                           | 4        |
+| Fed. R. Civ. P. 12(bX6)                                                         | I, 2, 18 |
+| Fed. R. Civ. P. 23.1                                                            | I, 2     |
+| Fed. R. Civ. P. 23.1(bX3)                                                       | 9        |
+
+Pursuant to Federal Rules of Civil Procedure 23.1 and 12(b)(6), Defendants' submit this memorandum of law in support of their motion to dismiss with prejudice the Amended Stockholder Derivative Complaint, dated June 30, 2023 (the "Complaint") [Dkt. 17].
+
+## I. Preliminary Statement
+
+Plaintiffs are stockholders of JPMorgan Chase & Co. ("JPMorgan" or the "Company") who assert derivative claims for breach of fiduciary duty against eight former and current directors and a former officer of JPMorgan. These claims concern the Company's prior relationship with Jeffrey Epstein, whose accounts at a Company subsidiary (the "Bank") were terminated in August 2013. For all its length, the 65-page Complaint contains few factual allegations about Defendants themselves—no doubt, because many of the Director Defendants were not even on the Board when Epstein was a Bank client, and those actually on the Board at the time are not alleged to have known about Epstein's accounts. The Complaint should be dismissed with prejudice because it both (1) fails to plead demand futility as a matter of law, and (2) fails to state claims for breach of fiduciary duty and unjust enrichment.
+
+Demand Futility Not Pleaded Shareholders may usurp the role of a company's board of directors and pursue claims belonging to the company only in rare circumstances. To displace that authority, Delaware law—which applies here because JPMorgan is incorporated in Delaware—requires that a shareholder first make a demand on the company's board to investigate the alleged claims. Compl. 60.2 Plaintiffs here concede that they did not make a
+
+I This memorandum is submitted on behalf of all defendants apart from James Staley, including JPMorgan; Stephen M, Todd Combs, James Crown, Timothy Flynn, Mellody Hobson, John Kessler, and Phebe Novakovic (the "Director Defendants"); and James Dimon (together, with the Director Defendants, the "Defendants"). JPMorgan joins only in Part III of this motion, addressing demand futility.
+
+<sup>2</sup> References to "Ex. \_ at \_" refer to the exhibits to the attached Declaration of Audra J. Soloway and the corresponding page citation. References to "I" refer to paragraphs in the Complaint.
+
+demand, instead contending that making a demand on the members of JPMorgan's Board as of the date the Complaint was filed (the "Demand Board") would be "futile." Compl. ¶I 185, 188.
+
+To surmount the stringent demand futility standard, however, Plaintiffs must plead that a majority of the Demand Board was conflicted because they (1) "received a material personal benefit from the alleged misconduct," (2) "would face a substantial likelihood of liability on any of the claims," or (3) "lack[] independence from someone" conflicted under (I) or (2). United Food & Com. Workers Union & Participating Food India. Emps.' Tri-State Pension Fund v. Zuckerberg, 262 A.3d 1034, 1058 (Del. 2021) ("Zuckerberg"). Rule 23.1 additionally requires that these facts be pled with particularity. The sparse, conclusory allegations of the Complaint, however, satisfy none of these prongs:
+
+- Under prong 1, there are no allegations whatsoever that any Demand Board Director received a material personal benefit from the alleged misconduct.
+- Under prong 2, the Complaint does not contain any well-pleaded facts, let alone particularized ones, establishing that any Demand Board Director faces a substantial likelihood of liability for the claims—let alone a majority of the Demand Board. Indeed, eight of the 11 Demand Board Directors joined the Board only after the Bank terminated Epstein's accounts in 2013, and face no risk of liability.
+- Under prong 3, the Complaint does not contain any well-pleaded facts that any Demand Board Director lacks independence from a purportedly conflicted Demand Board Director. As an initial matter, there are no conflicted Demand Board Directors. Moreover, the Complaint asserts only that certain Demand Board Directors have had long-standing business relationships with others, and that one director invested in a real estate venture decades ago in which Epstein was allegedly involved, which is plainly insufficient.
+- Accordingly, the Complaint lacks particularized factual allegations of demand futility to allow Plaintiffs to bring this action, and must be dismissed.
+
+Failure to State a Claim. Even if Plaintiffs had adequately pleaded demand futility (they have not), the breach of fiduciary duty claims fail to state a claim under Rule 12(b)(6) against both the non-management Director Defendants, as well as CEO Dimon.
+
+With respect to the non-management Director Defendants, Plaintiffs face the difficult hurdle of alleging oversight failure under the demanding standard set forth in In re Caremark Int? Inc. Derivative Litig., 698 A.2d 959 (Del. Ch. 1996). This hurdle is further heightened because JPMorgan's charter exculpates its directors from liability for breaches of fiduciary duty except those that arise from acts taken in bad faith or from intentional misconduct. The Complaint fails to identify any well-pleaded facts showing, as required by Caremark, that any Director Defendant consciously disregarded red flags concerning Epstein's accounts and banking activity. In fact, the Complaint does not plead that any Director Defendant even knew that Epstein was a client, much less that they disregarded the Bank's anti-money laundering obligations. Nor can the Complaint satisfy Caremark by alleging that the Director Defendants utterly failed to implement controls; to the contrary, it concedes that JPMorgan had robust internal controls for board oversight.
+
+With respect to Mr. Dimon, Plaintiffs likewise fail to plead allegations establishing (1) bad faith misconduct arising from a failure to act in the face of specific knowledge of any red flag (duty of oversight) or (2) that he acted with gross negligence with respect to compliance and risk management concerning Epstein's accounts (duty of care). Rather, the claims against Mr. Dimon are based on nothing more than pure speculation and innuendo. These allegations, more suited to Page Six of the New York Post than a complaint in federal court, fail to demonstrate Mr. Dimon was even involved in the decision to continue the banking relationship with Mr. Epstein or with BSA/AML issues concerning Mr. Epstein's accounts, much less state a failure of oversight claim.
+
+For all these reasons, the Complaint should be dismissed in its entirety with prejudice.
+
+## II. Relevant Background Facts as Pleaded in Complaint
+
+Plaintiffs' claims are premised on the Bank's relationship with Jeffrey Epstein from 2008, when Epstein pleaded guilty to soliciting a minor for prostitution, until his 2019 death. Comp/. 183. The Complaint's allegations are largely based on the claims advanced in two related cases pending before the Court, Jane Doe I v. JPMorgan Chase Bank, N.A., 22-cv-10019 (JSR) (S.D.N.Y. 2022) and Gov't of the U.S. Virgin Islands v. JPMorgan Chase Bank, N.A., 23 cv-10904 (S.D.N.Y. 2023). Defendants assume the Court's familiarity with the underlying allegations in these cases.
+
+Plaintiffs concede that they "did not make a demand on the Board [of JPMorgan] to institute this Action because pre-suit demand is excused." Compl. 185. For the reasons addressed below, a majority of the Demand Board is not conflicted for demand futility purposes, regardless of whether the Demand Board is deemed to have 11 members or 12 members (including Crown, who passed away on June 25, 2023, before this Complaint was filed).;
+
+Five Demand Board Directors—Linda Bammann, Alicia M, Alex Gorsky, Michael Neal, and Virginia Rometty—are current directors who are not named as defendants (the "Non-Defendant Directors"). The other current directors and Crown are named as Defendants, along with former director John Kessler, who served from 1996 to 2007. For the convenience of the Court, the below table sets forth the Demand Board and Director Defendants and their respective Board tenures, as well as whether Epstein was a Bank client during their board service:
+
+| Director         | Board Service | Defendant | On Board Before Epstein |
+|------------------|---------------|-----------|-------------------------|
+| Linda B. Bammann | 2013-Present  | No        | No                      |
+| Stephen B.       | 2004-Present  | Yes       | Yes                     |
+| Todd A. Combs    | 2016-Present  | Yes       | No                      |
+
+<sup>3</sup> See Daniel E. Slotnik, James Crown, Chicago Businessman and Avid Philanthropist, Dies at 70, N.Y. Times (July 3, 2023), nytimes.com/2023/06/27/business/james-crown-dead.html.
+
+| James S. Crown      | 2004-2023    | Yes | Yes |
+|---------------------|--------------|-----|-----|
+| Alicia B.           | 2023-Present | No  | No  |
+| James Dimon         | 2004-Present | Yes | Yes |
+| Timothy P. Flynn    | 2012-Present | Yes | Yes |
+| John W. Kessler     | 2004-2007    | Yes | Yes |
+| Alex Gorsky         | 2022-Present | No  | No  |
+| Mellody Hobson      | 2018-Present | Yes | No  |
+| Michael A. Neal     | 2014-Present | No  | No  |
+| Phebe N. Novakovic  | 2020-Present | Yes | No  |
+| Virginia M. Rometty | 2020-Present | No  | No  |
+
+Notably, eight of the Demand Board Directors—a clear majority—joined the Board only after the Bank terminated its banking relationship with Epstein in August 2013 (this includes all of the five Non-Defendant Directors, and Combs, Hobson, and Novakovic).° To address this inconvenient fact, the Complaint asserts that various Demand Board Directors face a "substantial likelihood of liability" because they "served on the Board at times between Epstein's 2008 plea and his 2019 death," Compl. ¶ 189, and that directors who served before 2013 face "an even more heightened likelihood of liability for having served...before the Company purportedly terminated its relationship with Epstein in 2013." Compl. ¶ 190.
+
+The Complaint contains no particularized factual allegations even suggesting that any Director Defendant was aware of the Bank's relationship with Epstein, much less consciously disregarded red flags or committed misconduct in connection with Epstein's accounts. Rather, to
+
+<sup>4</sup> The Complaint incorrectly states that Bammann joined the Board before Epstein was terminated as a client. Compl. ¶ 190. This is incorrect because Bammann did not join the Board until September 2013. Compare Doe 1 Compl. ¶ 473 ("By providing financing for Epstein's sex trafficking organization from about 2000 alf li about August 2013"); ¶ 438 ("[B]etween about 2000 and August 2013 and following, JP concealed its delivery of vast sums of cash to Epstein and his associates") with JPMorgan Names Two to Board, Creates Lead Director Role, Bloomberg (Sept. 9, 2013) https://www.bloomberg.cominews/articles/2013-09-09/jpmorgannames-two-to-board-creates-lead-director-role#xj4y7vzkg (dating Bammann joining the board to September 2013).
+
+the extent the Complaint contains any allegations with respect to any Director Defendant, those allegations are speculative assignations of guilt-by-association:
+
+- As to , Combs, Flynn, and Hobson, the Complaint contains no allegations whatsoever, apart from identifying them as Board members and detailing certain aspects of their professional backgrounds. Compl. 111135, 37-39.
+- Plaintiffs' only allegations against former director Crown are that, at some unspecified time decades ago, he "was involved in the New Albany project," a project to re-develop farmland into a town modeled on an 18th Century Georgian village, "which relied on Epstein for its success." Compl. ¶ 88, 194. Plaintiffs also allege that Crown recruited Dimon to Bank One Corporation, and that Crown served as the head of the JPMorgan Board of Directors' Risk Committee while Epstein was a client of the Bank. Compl. ¶¶ 14, 103, 104, 107.
+- With respect to Novakovic, Plaintiffs concede that she joined the Board after Epstein's death, see Compl. ¶ 36, but assert her non-independence from Crown on grounds that Novakovic is the CEO of General Dynamics, which is alleged to be Crown's "family business." Compl. ¶¶ 195, 12. Plaintiffs fashioned this purported conflict for the first time after Crown passed away, by adding Novakovic to a laterfiled pleading.5
+
+<sup>5</sup> The first-filed complaint did not sue Novakovic, and conceded her independence. [Dkt. 1] It was not until the second-filed complaint that Novakovic was added as a defendant and identified as purportedly conflicted due to her connection to Crown—but that complaint was filed on June 27, 2023 [City of Miami Gen. Emps. & Sanitation Emps. Retirement Trust v. JPMorgan Chase & Co., 23-cv-05459 (JSR) (S.D.N.Y. 2023), Dkt. I j after Crown's death on June 25, at which point any influence by Crown over Novakovic's consideration of a demand had plainly ceased. It is pure gamesmanship for Plaintiffs to sue Novakovic (who only joined the Board after Epstein's death) and assert her purported lack of independence only after Crown's death, when the purported conflict no longer exists. Further, Defendants asked Plaintiffs to dismiss their claims
+
+- Plaintiffs allege that former director Kessler, a corporate lawyer, had a business relationship with Les Wexner—an Epstein associate—and invested in the New Albany project on which Epstein worked decades ago, and in which Wexner, Kessler, and Epstein all invested and owned property. Compl. ¶¶ 11-13, 87-96, 105. Plaintiffs also allege the unremarkable fact that Kessler was involved in recruiting Dimon to join Bank One Corporation, which later merged with JPMorgan. Compl. ¶¶ 90-91, 96.
+- Finally, as to non-Defendant Bammann, Plaintiffs allege that she worked for Dimon in the early 2000s at both Bank One and at JPMorgan—years before joining the JPMorgan Board in September 2013. Compl. ¶ 193.
+
+The sole remaining allegation relevant to the non-management Director Defendants relates to government investigations and a jumble of inflammatory references to bad actors that Plaintiffs fail to show are in any way related to the Bank's prior relationship with Mr. Epstein. Compl. ¶¶ 170-73. Specifically, Plaintiffs allege that in January 2014, the Bank settled two BSA violations with the Office of the United States Attorney for the Southern District of New York. Compl. ¶ 170. In the settlement agreement, the Bank acknowledged that it had failed to report suspicious activity concerning the activities of Bernie Madoff between 2006 and 2008. Compl. 1 171; (Ex. I at I, 24). At the same time, the Bank agreed to pay a civil money penalty consent order to the OCC for \$350 million. Compl. ¶ 170.6 Plaintiffs also list, without any
+
+against Crown in light of his death, and Plaintiffs' response was to file this Amended Complaint on June 30, 2023 [Dkt. 17] that amended references to Crown's Board service to past tense, but did not dismiss him from the lawsuit. Defendants reserve all rights on this issue.
+
+<sup>6</sup> The government investigations related to the OCC consent order ultimately required JPMorgan and affiliates to improve compliance efforts, including with respect to suspicious activity reports ("SARs"). The Complaint does not allege that such improvements were not actually made in 2014, or that JPMorgan has violated the consent order.
+
+details, transactions that JPMorgan has purportedly handled for "bad actors" unrelated to Epstein, such as Jho Low and Paul Manafort. Comp1.1 172.7 None of this purported misconduct is alleged either to relate to Epstein, or to have been known by the Board.
+
+As to Mr. Dimon, the Bank's CEO, the Complaint's allegations are limited to (a) speculation that Mr. Dimon must have known of Mr. Epstein's criminality because, based on a lengthy, contorted story, Mr. Dimon and Mr. Epstein shared connections to the Columbus, Ohio business community (Compl. ¶¶ 14, 90-91, 96, 102-08, 191); (b) the assertion that a certain document concerning Epstein's bank accounts was marked "pending Dimon review:' though the Complaint conspicuously stops short of alleging that this review ever occurred (Compl. ¶¶ 19, 136-37, 191); and (c) the claim that Mr. Epstein and a different defendant, Mr. Staley, coordinated to schedule meetings for Mr. Dimon with the likes of Netanyahu, Bill Gates, and Prince Andrew, even though the Complaint nowhere pleads facts demonstrating Mr. Dimon attended these meetings or, if he did, that he had any knowledge of Mr. Epstein's purported involvement. Compl. ¶ 123.
+
+# III. No Demand Was Made, and Demand Futility Is Not Adequately Pleaded.
+
+# A. Legal Standard for Demand Futility
+
+"'A cardinal precept' of Delaware law 'is that directors, rather than shareholders, manage the business and affairs of the corporation.'" <sup>8</sup> Zuckerberg, 262 A.3d at 1047 (citation omitted). This extends to a determination whether the corporation should file a lawsuit against its directors, its officers, its controller, or an outsider. Id. A stockholder may substitute his
+
+<sup>7</sup>Plaintiffs also allege an equally irrelevant SEC fine concerning the deletion of electronic records which purportedly "includ[ed] emails and instant messages, dated from January to April 2018" but do not explain how this is relevant to Epstein at all. Comp1.1 173.
+
+<sup>8</sup> Because JPMorgan is incorporated in Delaware, Delaware law governing demand futility applies. Scalisi v. Fund Asset Mgmt., L.P., 380 F.3d 133, 138 (2d Cir. 2004).
+
+judgment for that of the board and assert company claims only after either "(I) mak[ing] a demand on the company's board of directors" that the board rejects "or (2) show[ing] that demand would be futile." Id.
+
+Federal Rule of Civil Procedure 23.1(b)(3) requires that a shareholder-derivative complaint "state with particularity" any "effort by the plaintiff to obtain the desired action from the directors" and "the reasons for not obtaining the action or not making the effort." It is the "rare case" where the requirement is excused based upon allegations that demand is futile. In re Citigroup Inc. S 'holder Derivative Litig., 964 A.2d 106, 121 (Del. Ch. 2009). To plead demand futility, Plaintiffs must allege "particularized facts creating a reasonable doubt that a majority of the Board...would be disinterested or independent in making a decision on" whether to bring suit. Roles v. Blasband, 634 A.2d 927, 930 (Del. 1993).
+
+To plead that directors are conflicted, Plaintiffs must allege with particularity that they (1) "received a material personal benefit from the alleged misconduct," (2) "would face a substantial likelihood of liability on any of the claims," or (3) "lack[' independence from someone" conflicted under (1) or (2). Zuckerberg, 262 A.3d at 1058. In this case, Plaintiffs make no allegation whatsoever that any director received a material personal benefit from any alleged misconduct (Compl. i 135-51), making prong one of Zuckerberg inapplicable? And Plaintiffs' efforts to satisfy prongs two and three plainly fail.
+
+<sup>9</sup> To support its unjust enrichment claim, Plaintiffs allege in conclusory fashion that Defendants "benefit[ed] from their misconduct in the form of profits, benefits, and other compensation." Compl. ¶ 217. But under Zuckerberg's first prong, ordinary board compensation does not constitute a material benefit. See e.g., In re Am. Intl Grp., Inc. Derivative Litig., 700 F. Supp. 2d. 419, 432 (S.D.N.Y. 2010), ard, 415 F. App'x 285 (2d Cir. 2011) (finding that "[p]laintiff s allegations regarding director compensation [did] not raise any reasonable doubt as to directorial disinterestedness" because plaintiff did not "allege that the compensation that these directors received was anything other than customary director compensation") (citing Orman v. Cullman, 794 A.2d 5, 29 n. 62 (Del. Ch. 2002)).
+
+### B. Plaintiffs Fail to Plead Particularized Facts Demonstrating that a Majority of the Demand Board Directors Face a "Substantial Likelihood of Liability."
+
+Demand may be excused under the second prong of the Zuckerberg test only in "rare" circumstances where a complaint alleges with particularity that a majority of directors engaged in such "egregious" misconduct that they face not merely a "threat" but a "substantial likelihood of director liability." Aronson v. 473 A.2d 805, 815 (Del. 1984). And here, Plaintiffs' hurdle is higher still: Pursuant to Delaware General Corporation Law Section 102(6)(7), JPMorgan's charter exculpates its directors from liability for breaches of fiduciary duty except those that arise from acts taken in bad faith or from intentional misconduct.10 See Ex. 2 at 4 (Restated Certificate of Incorporation of JPMorgan Chase & Co. at Art. 6(1)).
+
+In the face of this high pleading standard, Plaintiffs rely upon an oversight claim. Oversight claims are "possibly the most difficult theory in corporation law upon which a plaintiff might hope to win a judgment." In re Caremark, 698 A.2d at 967. To state such a claim, Plaintiffs must plead particularized facts demonstrating either that "(a) the directors utterly failed
+
+<sup>10</sup> As to the claim Plaintiffs seek to assert against Mr. Staley in particular, it is obvious that demand would not be futile. As noted above, JPMorgan has already brought claims against Mr. Staley identical to those that Plaintiffs now seek to assert on behalf of JPMorgan. See supra at Part III. Demand cannot be futile where, as here, a board has already acted on the very matter on which the shareholder demands action. See, e.g., In re Delta and Pine Land Co. S holders Litig., No. Civ.A. 17707, 2000 WL 875421, at •6 (Del. Ch. June 21, 2000) ("As this Court has previously found, the existence of a board-initiated action conclusively defeats any claim that demand would have been futile. Indeed, there is something to be said for the idea that this Court should inquire no further if it finds that the corporate directors are litigating the same claims advanced in the derivative action.") (internal quotation marks omitted); see also Kococinski v. MN, 935 F. Supp. 2d 909, 919 n.17 (D. Minn. 2013) (noting that "if a board of directors had already commenced a lawsuit addressing the conduct that a potential derivative plaintiff wanted to challenge, there would be little reason for the derivative plaintiff to commence the same action") (D. Minn. 2013); Meyers v. Keeler, 414 F. Supp. 935, 939 (W.D. Okla. 1976) (demand not futile where board has "already taken action on the very matter which [p]laintiff asserts they would not take action upon"). Indeed, permitting Plaintiffs' claim against Mr. Staley to proceed would simply result in unnecessary, duplicative litigation.
+
+to implement any reporting or information system or controls; or (b) having implemented such a system or controls, consciously failed to monitor or oversee its operations thus disabling themselves from being informed of risks or problems requiring their attention." v. Ritter, 911 A.2d 362, 370 (Del. 2006). In light of JPMorgan's exculpatory charter provision, "the lack of oversight pled must be so extreme that it represents a breach of the duty of loyalty," which "requires a pleading of scienter, demonstrating bad faith." Constr. Indus. Laborers Pension Fund v. Bingle, No. 2021-0940-SG, 2022 WL 4102492, at \*1 (Del. Ch. Sept. 6, 2022), aff'd, No. 411, 2022, 2023 WL 3513271 (Del. May 17, 2023). In other words, Plaintiffs must allege facts demonstrating that the Board "knew that internal controls were inadequate" but "chose to do nothing." Desimone v. Barrows, 924 A.2d 908, 940 (Del. Ch. 2007). The Complaint falls far short of meeting this rigorous pleading standard.
+
+## I. Eight Demand Board members assumed membership on the JPMorgan Board only after JPMorgan terminated Epstein as a client
+
+There is no colorable argument whatsoever that there is any risk of liability for at least eight of the Demand Board Directors—Defendants Combs, Hobson, Novakovic and non-Defendants Bammann, Rometty, Gorsky, Neal, and M —for the obvious reason that these directors all assumed their positions on JPMorgan's board only after Epstein's relationship with JPMorgan was terminated in August 2013. Compl. ¶¶ 36, 38, 39. These directors cannot possibly bear liability in connection with any alleged Epstein-related compliance shortcomings by the Bank before their Board membership began. See, e.g., In re Merrill & Co., Inc., Sec., Derivative & ERISA Litig., 773 F. Supp. 2d 330, 340 (S.D.N.Y. 2011) (JSR) (majority of Bank of America board faced no substantial risk of liability for claims alleged against Merrill officers and directors based on pre-merger conduct); United Food & Com. Workers Union v. Zuckerberg, 250 A.3d 862, 894 (Del. Ch. 2020) (holding that a board member was not
+
+interested in pan because he had joined the board after the challenged action had taken place), affd sub nom. Zuckerberg, 262 A.3d 1034.
+
+In the face of this critical deficiency, Plaintiffs lodge several speculative and conclusory allegations: First, Plaintiffs say that the Bank "potentially continued to engage with Epstein related entities until his death in jail in 2019" (Compl. ¶ 26), but the Complaint offers no wellpleaded factual allegations showing any continuing engagement with Epstein following termination of his accounts, much less a lack of oversight by Defendants from 2013-2019 so extreme that it amounts to bad faith. Second, Plaintiffs say that the Bank "actively concealed Epstein's crimes by failing to file any legally required Suspicious Activity Reports (`SARs'), which are mandated for large cash withdrawals and other suspicious transactions." Id. Plaintiffs, however, do not allege any particularized facts about the Company's actual SAR filing practices concerning Epstein—indeed, Plaintiffs rely fully on the USVI and Doe complaints (which actually plead that SARs were filed), and offer no good faith factual basis to support the conclusory and contradictory assertion that zero SARs were filed. Plaintiffs also fail to allege that any director would, in the ordinary course, have any knowledge of or involvement in the SAR filing process at a client-specific level, and therefore fail to allege that any director should have known about specific SAR filings related to Epstein. In any event, Plaintiffs again fail to explain how Directors who joined the Board after the Epstein account terminations could possibly be culpable for SAR filings, or the alleged lack thereof, during his tenure as a client.
+
+Accordingly, given that eight Demand Board Directors joined the Board after the Bank terminated Epstein's accounts in 2013, there is no question that a majority of an I I- (or 12-) person board faces no substantial risk of personal liability under the Zuckerberg analysis.
+
+#### 2. Plaintiffs fail to plead particularized facts demonstrating that the remaining Demand Board Directors knowingly failed to oversee internal controls.
+
+While not necessary to address, Plaintiffs also cannot satisfy Caremark for the Demand Board Directors who served while Epstein's accounts at the Bank were active—MI, Dimon, and Flynn (and Crown, even if included). To satisfy Caremark, both knowledge of the misconduct and a conscious failure to act upon that knowledge are required. See Firemen's Ret. Sys. of St. Louis v. Sorenson, No. CV 2019-0965-LWW, 2021 WL 4593777, at •13 (Del. Ch. Oct. 5, 2021) (plaintiff must allege directors "knew about 'red flags' alerting them to corporate misconduct and consciously failed to act after learning about evidence of illegality") (internal quotation marks omitted). Importantly, merely pleading facts that "imply that the [demand board] could have done a better job addressing the issues highlighted by, among other sources, .. . consent orders" is "not enough to state a Caremark claim." Okla. Firefighters Pension & Ret. Sys. v. Corbat, No. CV 12151-VCG, 2017 WL 6452240, at \*17 (Del. Ch. Dec. 18, 2017).
+
+The Complaint is devoid of well-pleaded factual allegations that the Demand Board Directors who served while Epstein was a Bank client (or any other director) were even aware of that banking relationship, let alone were aware of any red flags concerning Epstein's accounts and thereafter consciously disregarded a duty owed by the Board to act on such red flags, as is required to sustain a claim under the second Caremark prong. See Pettry v. M, C.A. No. 2019-0795-JRS, 2021 WL 2644475, at •7 (Del. Ch. Jun. 28, 2021). Even the Complaint's allegations that Staley was involved in Epstein's crimes does not in any way suggest the Board was informed of issues concerning Epstein's accounts. Compl.lili 139-50. Entirely absent, therefore, are any allegations that any Director Defendant was ever "presented with 'red flags' alerting it to potential misconduct" and consciously and deliberately ignored such warnings, as
+
+required to state a prong-two Caremark claim. David B. Shaev Profit Sharing Acct. v. Armstrong, No. Civ.A. 1449-N, 2006 WL 391931, at \*5 (Del. Ch. Feb. 13, 2006), aff'd, 911 A.2d 802 (Del. 2006); South v. Baker, 62 A.3d I, 17 (Del. Ch. 2012) (no substantial likelihood of liability where "[a]lthough the complaint asserts that the directors knew of and ignored [certain safety incidents], the complaint nowhere alleges anything that the directors were told about the incidents, what the Board's response was, or even that the incidents were connected in any way").
+
+Nor does the mere existence of the alleged regulatory investigations or enforcement actions in 2013 and 2014 support a Caremark claim for the Director Defendants on the Board at that time. See Comp1.11 170-71. The DOJ settlement, OCC fine, and other allegations set forth in the Complaint did not concern the Bank's relationship with Epstein, which had already been terminated. Compl. 11 172-73; see In re SAIC Derivative Litig., 948 F. Supp. 2d 366,387 (S.D.N.Y. 2013) (rejecting argument that "knowledge of wrongdoing in other transactions should have put the Board on a heightened state of alert"); Citigroup, 964 A.2d at 129 (rejecting contention that "alleged prior, unrelated wrongdoing would make directors sensitive to similar circumstances") (internal quotation marks omitted). Moreover, if anything, the Director Defendants on the Board at the time of the government settlements would have been reassured by enhancement of the Company's compliance procedures—and the Complaint does not allege that these enhancements were not actually made, or that the Board subsequently learned of any SAR-related compliance problems following those government investigations in 2014. Plaintiffs thus fail to allege "information regarding the individual [directors' responses, if any" to the alleged regulatory enforcement, and thus fail to establish that any "[d]irector[] failed to act or
+
+[that] the actions they took were inappropriate in light of the information they received." In re 177 Corp. Derivative Litig., 588 F. Supp. 2d 502, 513 (S.D.N.Y. 2008).
+
+In sum, where, as here, the Complaint fails to offer "well-pled, particularized allegations of fact detailing the precise roles" the Demand Board Directors played, the information that came to their attention, "and any indication as to why they would have perceived the [complained of] irregularities," Plaintiffs cannot sustain a claim that such directors face a significant risk of liability. Guttman v. Mang. 823 A.2d 492, 503 (Del. Ch. 2003).
+
+## 3. Plaintiffs fail to plead particularized facts demonstrating the Directors' "utter failure" to implement any internal controls.
+
+Plaintiffs also fail to satisfy Caremark by pleading that the Demand Board Directors "utterly failed to implement any reporting or information system or controls." M, 911 A.2d at 370. "The issue [under prong one of Caremark] is not whether JPMorgan's controls were adequate, but whether any existed." Steinberg v. Dimon, No. 14 Civ. 688 (PAC), 2014 WL 3512848, at \*3 (S.D.N.Y. July 16, 2014). The standard "requires only that a reporting system exist, not even that it be `reasonable.'" Corp. Risk Holdings LLC v. Rowlands, No. 17-CV-5225 (RJS), 2018 WL 9517195, at \*5 (S.D.N.Y. Sept. 28, 2018) (quoting Cent. Laborers' Pension Fund v. Dimon, 638 F. App'x 34, 37-38 (2d Cir. 2016)). "[S]o long as directors `try' to implement such system, they discharge their duty to monitor the corporation." Kravitz v. Taviarios, No. 19 Civ. 8438 (NRB), 2020 WL 3871340, at \*9 (S.D.N.Y. July 8, 2020), aff'd, No. 20-2579-CV, 2021 WL 5365582 (2d Cir. Nov. 18, 2021). Indeed, under the first prong of Caremark, "plaintiffs usually lose because they must concede the existence of board-level systems of monitoring and oversight such as a relevant committee, a regular protocol requiring board-level reports about the relevant risks, or the board's use of third-party monitors, auditors,
+
+or consultants." v. Ellison, C.A. No. 2018-0755-AGB, 2019 WL 3408812, at •9 (Del. Ch. Jul. 29, 2019) (quoting Marchand v. Barnhill, 212 A.3d 805, 823 (Del. 2019)).
+
+That is the case here. The Complaint concedes that robust systems do exist at JPMorgan to identify suspicious activity. Comp!. ¶ 2. The Complaint also quotes from internal memoranda written by officials in JPMorgan's risk management, Global Corporate Security, compliance, and other unspecified functions, acknowledging that internal reporting processes existed and were leveraged by employees. See Compl. ¶¶ 24, 146, 151, 154. In addition, the Complaint describes the numerous committees of the JPMorgan Board of Directors: it acknowledges the Bank's Audit and Risk Committees by mentioning directors' memberships on them, and referencing their responsibilities. See Compl. ¶¶ 33, 37-39, 104, 112, 170. The existence of these committees alone "refutes the assertion that the directors utterly failed to attempt to fulfill their oversight obligations," Baker, 62 A.3d at 18 (internal quotation marks omitted), and preclude any claim by Plaintiffs based on Caremark's first prong.
+
+## C. Plaintiffs Fail to Plead Particularized Facts Demonstrating That Any Demand Board Director "Lacks Independence."
+
+The Complaint also does not plead facts sufficient to satisfy the third prong of the Zuckerberg test—that "at least half of the members of the Demand Board" `lack[] independence from someone who received a material personal benefit from the alleged misconduct that is the subject of the litigation demand or who would face a substantial likelihood of liability on any of the claims that are the subject of the litigation demand." Zuckerberg, 262 A.3d at 1058-59. Importantly, "(i)n the demand futility context, directors are presumed to be independent." Teamsters Union 25 Health Servs. & Ins. Plan v. Baiera, 119 A.3d 44, 59 (Del. Ch. 2015) (internal quotation marks omitted). To overcome this presumption, a plaintiff must allege that half of the directors "had ties to the person whose proposal or actions he or she is evaluating that
+
+are sufficiently substantial that he or she could not objectively discharge his or her fiduciary duties." Kahn v. M & F Worldwide Corp., 88 A.3d 635, 649 (Del. 2014), overruled on other grounds by Flood v. Synutra Int 7, Inc., 195 A.3d 754 (Del. 2018).
+
+Plaintiffs allege that Bammann and Crown (even if relevant) were not independent from CEO Dimon (who purportedly faces a substantial risk of liability), and that Crown separately faces a substantial risk of liability because of his unspecified involvement decades ago in the New Albany development project, creating a purported conflict for Novakovic. These arguments fail for numerous reasons:
+
+First, for the reasons stated infra. Dimon and Crown do not face a substantial risk of liability and therefore are not conflicted.
+
+Second, even if Dimon faced a substantial risk of liability, Bammann and Crown do not lack independence from Dimon. Plaintiffs allege Bammann "owes a significant portion of her professional success to Dimon" simply because she worked with him at Bank One Corporation and then JPMorgan in the early 2000s. Comp!. ¶ 193. Similarly, Plaintiffs point to Crown's board service for Bank One when Dimon was CEO and his support for Dimon at both Bank One and JPMorgan. Compl. ¶ 194. Courts routinely hold that merely asserting close personal or business relationships is insufficient to plead lack of independence in the demand futility context.
+
+In re Stanley Derivative Litig., 542 F. Supp. 2d 317, 326 (S.D.N.Y. 2008); see also Beam ex reL Martha Stewart Living Omnimedia, Inc. v. Stewart, 845 A.2d 1040, 1051-52 (Del. 2004) ("Mere allegations that [the directors] move in the same business and social circles, or a characterization that they are close friends, is not enough to negate independence for demand excusal purposes."); Rahbari v. Oros, 732 F. Supp. 2d 367, 388 n. 24 (S.D.N.Y. 2010) ("[M]ere personal or business relationships will not raise a reasonable inference that a director cannot consider demand, absent specific factual allegations to support such a conclusion").
+
+Third. Plaintiffs cannot disqualify Crown as an independent director merely by citing the decades-ago New Albany real estate venture in which Crown purportedly was "involved" in some unspecified way, and for which Epstein was purportedly brought in to restructure and invest. The Complaint offers no facts explaining Crown's involvement, whether he even had any contact with Epstein, or whether he had any financial entanglements with Epstein—much less any connection that is relevant decades later. Compl. ¶¶ 11, 105. The mere coincidence that both Crown and Epstein (along with many others) were involved in a long-ago real estate project certainly cannot create a substantial likelihood of liability for Crown (much less, by extension, Novakovic, who allegedly was employed by Crown's family business).
+
+# IV. Plaintiffs Have Failed to State a Claim Against Any Defendant.
+
+# A. Legal Standard Under Rule 12(6)(6)
+
+Even if demand futility were pleaded (it is not), to survive a motion to dismiss under Rule I2(b)(6), the Complaint "must contain sufficient factual matter, accepted as true, to `state a claim to relief that is plausible on its face."' Ashcroft v. lqbal, 556 U.S. 662, 678 (2009) (quoting Bel Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)).
+
+## B. The Complaint Fails to State a Fiduciary Duty Claim Against Any Director Defendant
+
+For the same reasons that Plaintiffs have failed to plead that any Demand Board Director faces a substantial risk of liability, see supra Part(111)(8)(1), Plaintiffs have also failed to state a claim against any Director Defendant for breach of fiduciary duty. As elaborated above, because JPMorgan's charter exculpates its directors from liability for breaches of fiduciary duty, except those that arise from acts taken in bad faith or from intentional misconduct, JPMorgan's Director
+
+Defendants face no possibility of liability for claims based on negligence, gross negligence, or any other conduct short of bad faith. Instead, Plaintiffs must plead scienter demonstrating bad faith. Bing/e, 2022 WL 4102492, at \*1. Further, as noted above, the Caremark claims asserted here are "possibly the most difficult theory in corporation law upon which a plaintiff might hope to win a judgment" and are routinely dismissed. Caremark, 698 A.2d at 967.
+
+The Complaint does not even attempt to plead the bad faith conduct of the Director Defendants Crown, =, Flynn, Hobson, Combs and Novakovic. As addressed above, breach of a fiduciary duty under a Caremark oversight theory cannot be satisfied merely by offering conclusory allegations that directors were aware (or should have been aware) of wrongful conduct. Here, there are simply no particularized allegations that any Director Defendant knew of Epstein's conduct, knew of Epstein's status as a client at the Bank, failed in any manner to respond to red flags regarding Epstein or JPMorgan's SAR or other BSA/AML compliance policies or practices, or otherwise failed in any way in executing their oversight duties (indeed, Defendants Combs, Hobson, and Novakovic were not even on the Board when Epstein was a client at the Bank). See supra pp. 11-12."
+
+As to Kessler, a corporate lawyer who was a director of JPMorgan from 1995-2007, Plaintiffs allege that Kessler associated with Wexner, including in the New Albany real estate venture, on which Epstein supposedly also worked and invested. Comps. 99 11-14,34,87-93, 194. Even crediting these conclusory allegations, they amount to nothing more than a thin thread
+
+<sup>&</sup>quot; Plaintiffs half-hearted attempts at alleging knowledge of Epstein's crimes by the Director Defendants are not only generalized but also patently speculative. See, e.g., Comp!. ¶ 5 (speculating that JPM executives who were aware of Epstein-related issues "presumably" attended Board meetings); id. (opining that Board members, by virtue of intelligence and business acumen, "very likely were aware" of Epstein's misconduct). This rank speculation is plainly inadequate.
+
+tying Kessler to Epstein through a common business partner and venture—entirely disconnected from Epstein's JPMorgan accounts or the activities at issue in Doe and USVI. These allegations certainly do not plead that Kessler "knew of evidence of corporate misconduct... yet acted in bad faith by consciously disregarding [his] duty to address [it]." Peaty, 2021 WL 2644475, at \*7.
+
+# C. The Complaint Fails to State a Fiduciary Duty Claim Against Mr. Dimon
+
+The Court also should dismiss Plaintiffs' claim that Mr. Dimon breached his fiduciary duties for failure to meet the "most difficult theory" imposed under Caremark.
+
+The Complaint principally alleges that Mr. Dimon breached his duty of loyalty, under Caremark, by allegedly failing to oversee risks arising from Epstein's banking activities. See Compl. ¶ 212. Caremark claims have historically concerned directors; Delaware law only very recently extended them to officers. In re McDonald's Corp. S'holder Derivative Litig., 289 A.3d 343, 358 (Del. Ch. 2023). In McDonald's, the Court declined to dismiss a Caremark claim against the Global Chief People Officer of McDonalds because he ignored 18 particularly pleaded red flags indicating the executive's plain and obvious awareness that the company was violating law prohibiting sexual harassment. Id. at 359. The red flags included, for example: (i) complaints about the conduct of executives; (ii) two instances in which a dozen employees complained to the EEOC about sexual harassment and misconduct; (iii) a company walkout across thirty cities to protest sexual harassment; (iv) the defendant officer's personal engagement in sexual harassment witnessed by 30 employees, leading to discipline by the audit committee; (v) letters from U.S. Senators probing sexual harassment; and (vi) receiving specific information that the CEO was engaged in a prohibited relationship with an employee. Id. at 378. Thus, the court drew a pleadings stage inference that the defendant consciously and in bad faith ignored red flags that the company engaged in sexual harassment and misconduct. Id. at 379.
+
+Here, Plaintiffs seek to pursue a red flag theory of liability against Mr. Dimon. See Compl. ¶ 212.12 But in stark contrast to McDonald's, the allegations relating to Mr. Dimon are largely fantastical, unrelated to any knowledge of Epstein, much less Epstein's criminal activities, and thus come nowhere close to stating a claim. Unlike the allegations in McDonald's, there are no allegations of the widespread, obvious awareness generated by things like public walkouts across the nation, letters from U.S. Senators, or dozens of complaints to U.S. agencies. Fatally, the Complaint fails to allege that Mr. Dimon had any actual role in the decision to retain Mr. Epstein as a client or any role in SARs filings, BSA/AML compliance, or reporting of potential wrongdoing to law enforcement. Likewise, the Complaint fails to allege with specificity that Mr. Dimon was aware of any red flags concerning Epstein's criminal activities, much less that he personally engaged in the purported red flag behavior like the officer in McDonald's. This is fatal because, under McDonald's, to establish breach of the duty of oversight, plaintiffs must establish that the officer was in fact responsible for receiving and addressing the supposed red flags. See M re McDonald's, 289 A.3d at 350.
+
+Plaintiffs cannot salvage a claim by offering mere speculation based on a single document that neither is addressed to nor copied Mr. Dimon, referring to a potential "Dimon review." Compl. ¶' 19, 136. The Complaint does not identify the employee who sent the email or explain the nature of the supposed "review." Further, the Complaint conspicuously fails to allege that the review occurred.13 This is no doubt because Plaintiffs have no ground to believe
+
+<sup>12</sup> The Complaint does not assert officer liability under Caremark prong one (Le., failure to set up monitoring). Nor could it, since the Complaint instead takes the tack of asserting (unsuccessfully) that information about Epstein's activities was available.
+
+<sup>13</sup> See Compl. 1 19 ("Whether Staley blocked the expected 'Dimon review' or someone with authority (such as Dimon or a Board member) provided informal and tacit support to Epstein and thus obviated the formal "Dimon review" process, Epstein remained with 1PM."), id. ¶ 136 ("The fact that Epstein's account status was expected to be presented to Dimon suggests either
+
+that the review occurred. And, even if such a review did occur (which the Complaint does not allege), the Complaint fails to plead what information was made available to Mr. Dimon or what decision he even purportedly made.
+
+None of the Complaint's other allegations are sufficient either. The long and winding story of Mr. Epstein's supposed connections to members of the Columbus business community and the utterly unrelated support for Mr. Dimon from the Columbus business community is pure innuendo. The Complaint nowhere alleges that any of Mr. Dimon's Columbus business contacts introduced Mr. Epstein to Mr. Dimon, much less alerted Mr. Dimon about Mr. Epstein's sexual crimes or raised any concern to Mr. Dimon about JPMorgan's due diligence or compliance efforts with respect to Mr. Epstein's accounts. The Complaint similarly does not allege that Mr. Dimon was aware that Mr. Epstein was involved in the meetings Mr. Staley purportedly attempted to schedule on Mr. Dimon's behalf, that those meetings occurred, or that, even if the meetings occurred, Mr. Dimon would have learned anything about Mr. Epstein's criminality or JPMorgan's compliance efforts through said meetings.
+
+Finally, separate from and in addition to all the failings already pointed out, none of these allegations come close to establishing any basis for inferring that Mr. Dimon acted in conscious bad faith—an absolute prerequisite to Plaintiffs' claim under Delaware law. See Horman v. Abney, No. CV 12290-VCS, 2017 WL 242571, at \*9 (Del. Ch. Jan. 19, 2017) (even if reporting systems did not prevent corporate wrongdoing, no oversight claim without bad faith). At bottom, the Complaint against Mr. Dimon seeks impermissibly to articulate a res ipso loquitur theory—Mr. Epstein engaged in abhorrent conduct, the Bank allegedly failed to comply with
+
+that it was (as per known internal protocols) or that the matter was resolved in favor of keeping Epstein without forcing Dimon to leave a paper trail of his involvement in the matter.").
+
+BSA/AML requirements with respect to Epstein's accounts or timely close those accounts, Mr. Dimon was the Chairman of the Board and CEO, so he must be responsible. But such theories are insufficient: "Delaware courts routinely reject the conclusory allegation that because illegal behavior occurred, internal controls must have been deficient, and [defendants] must have known so." Genworth Fin., Inc. ConsoL Derivative Litig., No. CV 11901-VCS, 2021 WL 4452338, at '13 (Del. Ch. Sept. 29, 2021).
+
+To the extent the Complaint purports to assert that Mr. Dimon breached his duty of care, see, e.g., Compl. 1 209, the Court should also dismiss that claim. "The fiduciary duty of care requires that officers and directors both: (1) use that amount of care which ordinarily careful and prudent men would use in similar circumstances; and (2) make business decisions by consider[ing] all material information reasonably available." In re: Old Bpsush, Inc., No. 16- 12373 (BLS), 2021 WL 4453595, at \*8 (D. Del. Sept. 29, 2021) (internal quotation marks omitted). A breach of the duty of care requires a showing of "gross negligence." Id. Plaintiffs must "plausibly show[]" that the Mr. Dimon was "recklessly uninformed or acted outside of the bounds of reason." Id. (internal quotation marks omitted).
+
+The Complaint does not plausibly show that Mr. Dimon acted with "gross negligence" for the same reasons that it fails to allege he acted in bad faith, that he had knowledge that the Company allegedly was not complying with BSA/AML requirements with respect to Epstein's accounts, or that he even had any role in BSA/AML compliance relating to Epstein's accounts. Instead, the allegations are purely conclusory. See, e.g., Harcwn v. Lovoi, C.A. No. 2020-0398- PAF, 2022 WL 29695, at \*26-27 (Del. Ch. Jan. 3, 2022) (dismissing duty of care claims where allegations as to officers' conduct were conclusory); City of Gen. Emps.' Ret. Sys. v.
+
+Roche, 2020 WL 7023896, at •19 (Del. Ch. Nov. 30, 2020) (dismissing duty of care claim where complaint did not allege that officers were involved in allegedly misleading proxy).
+
+# D. The Complaint Fails to State a Claim for Unjust Enrichment
+
+Finally, Plaintiffs have also failed to state a claim against any Defendant for unjust enrichment. Under Delaware law, a claim of unjust enrichment requires showing "(1) an enrichment, (2) an impoverishment, (3) a relation between the enrichment and impoverishment, (4) the absence of justification and (5) the absence of a remedy provided by law." Cantor Fitzgerald, L.P. v. Cantor, 724 A.2d 571, 585 (Del. Ch. 1998).
+
+Plaintiffs' claim fails at the outset, as the Complaint does not contain well-pleaded facts suggesting that a single Defendant was enriched beyond their ordinary compensation. See Compl. 217; In re Pfizer Inc. S 'holder Derivative Ling., 722 F. Supp. 2d 453, 465-66 (S.D.N.Y. 2010) (applying Delaware law and denying claims for unjust enrichment absent support for the proposition "that the mere retention of directors' and officers' ordinary compensation can sustain an unjust enrichment claim predicated on allegations that these defendants breached their fiduciary duties"). Plaintiffs also make no allegation that they were "impoverished" by the Defendants' ordinary compensation, and therefore cannot satisfy any of the remaining elements of the five-part test under Cantor.
+
+Plaintiffs' claim for unjust enrichment also fails because it is premised solely on Plaintiffs' breach of fiduciary duty claim—which itself is deficient for the reasons stated above. See supra Section IV.B—C. Under Delaware law, "[a]t the pleadings stage, an unjust enrichment claim that is entirely duplicative of a breach of fiduciary duty claim ... is frequently treated in the same manner when resolving a motion to dismiss." Caspian Select Credit Fund Ltd. v. Gold, No. CV 10244-VCN, 2015 WL 5718592, at •16 (Del. Ch. Sep. 28, 2015) (quoting
+
+Ca!ma ex rel. Citrix Sys., Inc. v. Templeton, 114 A.3d 563, 591 (Del. Ch. 2015)). Here, the unjust enrichment claim is explicitly predicated on Defendants' alleged breaches of fiduciary duties. Comp1.111 217, 219 (alleging Defendants should not retain the unspecified benefits they allegedly received "only by virtue of breaching their fiduciary duties"). Defendants' alleged unjust enrichment is therefore "not separate or distinct from the alleged breach of fiduciary duty, except as to the existence of such a duty." Manbro Energy Corp. v. Chatterjee Advisors, LLC, No. 20 CIV. 3773 (LGS), 2021 WL 2037552, at \*9 (S.D.N.Y. May 21, 2021) (applying Delaware law).
+
+Accordingly, the unjust enrichment claim should be dismissed both because no actual enrichment is alleged, and because it is duplicative of the defective fiduciary duty claim.
+
+# V. Conclusion
+
+For the foregoing reasons, the Complaint should be dismissed with prejudice.10
+
+Dated: July 6, 2023
+
+<sup>14</sup> Any dismissal should be with prejudice, as Plaintiffs have already filed two prior complaints prior to the operative complaint. Certainly Plaintiffs should not be permitted to amend to add allegations that were already public when the Complaint was filed — particularly given that the claims are based on allegations brought in two related cases pending before the Court, Jane Doe I v. JPMorgan Chase Bank, 22-cv-10019 (JSR) (S.D.N.Y. 2022), and U.S. Virgin Island v. JPMorgan Chase Bank, N.A., 23-cv-10904 (S.D.N.Y. 2023), and significant Epstein-related materials have been released into the public domain from these cases and other sources.
+
+### WILMER CUTLER PICKERING HALE AND DORR LLP
+
+By: /s/ Timothy Perla Timothy Perla 60 State Street Boston, 02109 (t) (617) 526-6000 (0 (617) 526-5000 timothy.perla@wilmerhale.com
+
+Noah A. Levine 7 World Trade Center 250 Greenwich Street New York, NY 10007 (t) (212) 230-8800 (0 (212) 230-8888 noah.levine@wilmerhale.com
+
+### PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
+
+By: Is/ Audra J. Solowav Audra J. Soloway Jessica S. Carey Jacobus J. Schutte 1285 Avenue of the Americas New York, NY 10019-6064 Phone: (212) 373-3000 Fax: (212) 757-3990 asoloway®paulweiss.com
+
+Counsel for Director Defendants Stephen B. , Todd A. Combs, James S. Crown, Timothy P. Flynn, Mellody Hobson, John W. Kessler, and Phebe N. Novakovic
+
+Counsel for Defendants JPMorgan Chase & Co. and James Dimon
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02822958/EFTA02822958.md b/marker2/court-pension-v-dimon/EFTA02822958/EFTA02822958.md
new file mode 100644
index 0000000000000000000000000000000000000000..8118fdd6e60c7576f109098873ad4fa89b993d89
--- /dev/null
+++ b/marker2/court-pension-v-dimon/EFTA02822958/EFTA02822958.md
@@ -0,0 +1,551 @@
+# EXHIBIT 1
+
+![](_page_1_Picture_1.jpeg)
+
+United States Attorney Southern District of New York
+
+The SIM\*J. Mono Budding One Saint Andizny's Plaza New York. New York 10007
+
+January 6, 2014
+
+John F. Savarese, Esq. Stephen R. DiPrima, Esq. Emil A. Kleinhaus Es Wachtell, Lipton, I= & Katz 51 West 52" Street New York, New York 10019
+
+Steven IL Peikin, Esq. & Cromwell LLP 125 Broad Street New York, New York 10004
+
+Re: JPMorgan Chase Bank, N.A. — Deferred Prosecution Agreement
+
+Dear Messrs. Savarese, DiPrima, Kleinhaus, and Peikin:
+
+Pursuant to our discussions and written exchanges, the Office of the United States Attorney for the Southern District of New York (the "Office") and defendant JPMorgan Chase Bank, N.A. ("JPMorgan" or the "Bank"), under authority granted by its Board of Directors in the form of a Board Resolution (a copy of which is attached hereto as Exhibit A), hereby enter into this Deferred Prosecution Agreement (the "Agreement").
+
+# The Criminal Information
+
+1. JPMorgan consents to the filing of a two-count Information (the "Information") in the United States District Court for the Southern District of New York (the "Court"), charging JPMorgan with failure to maintain an effective anti-money laundering program, in violation of Title 31, United States Code, Sections 5318(h) and 5322(a) and Title 12, Code of Federal Regulations, Section 21.21, and failure to file a suspicious activity report, in violation of Title 31, United States Code, Sections 5318(g) and 5322(a) and Title 12, Code of Federal Regulations, Section 21.11. A copy of the Information is attached hereto as Exhibit B. This Agreement shall take effect upon its execution by both parties.
+
+# Acceptance of Responsibility
+
+2. JPMorgan admits and stipulates that the facts set forth in the Statement of Facts, attached hereto as Exhibit C and incorporated herein, are true and accurate.
+
+### **Payments and Forfeiture Obligation**
+
+3. As a result of the conduct described in the Information and the Statement of Facts, JPMorgan agrees to make a payment in the amount of \$1,700,000,000 (the "Stipulated Forfeiture Amount") to the United States, pursuant to this Agreement.
+
+4. JPMorgan agrees that this Agreement, the Information, and the Statement of Facts may be attached and incorporated into a civil forfeiture complaint (the "Civil Forfeiture Complaint"), a copy of which is attached hereto as Exhibit D, that will be filed against the Stipulated Forfeiture Amount. By this Agreement, JPMorgan expressly waives service of that Civil Forfeiture Complaint and agrees that a Final Order of Forfeiture may be entered against the Stipulated Forfeiture Amount.
+
+5. JPMorgan shall transfer \$1,700,000,000 to the United States within three business days after executing this Agreement (or as otherwise directed by the Office following such period). Such payment shall be made by wire transfer to the United States Marshals Service, pursuant to wire instructions provided by the Office. If JPMorgan fails to timely make the payment required under this paragraph, interest (at the rate specified in 28 U.S.C. § 1961) shall accrue on the unpaid balance through the date of payment, unless the Office, in its sole discretion, chooses to reinstate prosecution pursuant to Paragraphs 14 and 15, below.
+
+6. Upon Court approval of this Agreement, JPMorgan shall release any and all claims it may have to the Stipulated Forfeiture Amount and execute such documents as necessary to accomplish the forfeiture of the funds. JPMorgan agrees that it will not file a claim with the Court or otherwise contest the civil forfeiture of the Stipulated Forfeiture Amount and will not assist a third party in asserting any claim to the Stipulated Forfeiture Amount. The Government intends to distribute the Stipulated Forfeiture Amount to victims of the fraud at Bernard L. Madoff Investment Securities LLC and its predecessor, Bernard L. Madoff Investment Securities (collectively, "Madoff Securities"), consistent with the applicable Department of Justice regulations, through the ongoing remission process. *See* 21 U.S.C. § 853(i)(1) and 28 C.F.R. Part 9.
+
+7. JPMorgan agrees that the Stipulated Forfeiture Amount shall be treated as a penalty paid to the United States government for all purposes, including all tax purposes. JPMorgan agrees that it will not claim, assert, or apply for a tax deduction or tax credit with regard to any federal, state, local or foreign tax for any portion of the \$1,700,000,000 that JPMorgan has agreed to pay to the United States pursuant to this Agreement.
+
+### **Obligation to Cooperate**
+
+8. JPMorgan agrees to cooperate fully with the Office, the Federal Bureau of Investigation ("FBI"), and any other governmental agency designated by the Office regarding any matter relating to the conduct described in the Information or Statement of Facts, or any
+
+matter relating to the fraud committed at Madoff Securities (collectively, the "Office's Investigation").
+
+9. It is understood that during the term of this Agreement, and consistent with its obligations under law, including relevant data protection, bank secrecy, or other confidentiality laws, JPMorgan shall, with respect to the Office's Investigation: (a) truthfully and completely disclose all information with respect to the activities of the Bank and its officers, agents, affiliates, and employees concerning all matters about which the Office inquires of it, which information can be used for any purpose; (b) cooperate fully with the Office, the FBI and any other governmental agency designated by the Office; (c) attend all meetings at which the Office requests its presence and use its reasonable best efforts to secure the attendance and truthful statements or testimony of any past or current officers, agents, or employees at any meeting or interview or before the grand jury or at trial or at any other court proceeding; (d) provide to the Office upon request any document, record, or other tangible evidence relating to matters about which the Office or any designated law enforcement agency inquires of it; (e) assemble, organize, and provide in a responsive and prompt fashion, and upon request, on an expedited schedule, all documents, records, information and other evidence in JPMorgan's possession, custody or control as may be requested by the Office, the FBI, or designated governmental agency; (f) provide to the Office any information and documents that come to JPMorgan's attention that may be relevant to the Office's Investigation, as specified by the Office; (g) provide testimony or information necessary to identify or establish the original location, authenticity, or other basis for admission into evidence of documents or physical evidence in any criminal or other proceeding as requested by the Office, the FBI, or designated governmental agency, including but not limited to information and testimony concerning the conduct set forth in the Information and Statement of Facts. Nothing in this Agreement shall be construed to require JPMorgan to provide any information, documents, or testimony protected by the attorney-client privilege, work-product doctrine, or other applicable privileges.
+
+10. It is understood that, during the term of this Agreement, JPMorgan shall: (a) bring to the Office's attention all criminal conduct by JPMorgan or any of its employees acting within the scope of their employment related to violations of the federal laws of the United States, as to which JPMorgan's Board of Directors, senior management, or United States legal and compliance personnel are aware; (b) bring to the Office's attention any administrative, regulatory, civil, or criminal proceeding or investigation of JPMorgan relating to the Bank Secrecy Act ("BSA"); and (c) commit no crimes under the federal laws of the United States subsequent to the execution of this Agreement.
+
+11. JPMorgan agrees that its obligations pursuant to this Agreement, which shall commence upon the signing of this Agreement, will continue for two years from the date of the Court's acceptance of this Agreement, unless otherwise extended pursuant to Paragraph 16 below. JPMorgan's obligation to cooperate is not intended to apply in the event that a prosecution against JPMorgan by this Office is pursued and not deferred.
+
+### Deferral of Prosecution
+
+12. In consideration of JPMorgan's entry into this Agreement and its commitment to: (a) accept and acknowledge responsibility for its conduct, as described in the Statement of Facts and the Information; (b) cooperate with the Office and the FBI; (c) make the payment specified in this Agreement; (d) comply with the federal criminal laws of the United States (as provided herein in Paragraph 10); and (e) otherwise comply with all of the terms of this Agreement, the Office shall recommend to the Court that prosecution of JPMorgan on the Information be deferred for two years from the date of the signing of this Agreement. JPMorgan shall expressly waive indictment and all rights to a speedy trial pursuant to the Sixth Amendment of the United States Constitution, Title 18, United States Code, Section 3161, Federal Rule of Criminal Procedure 48(b), and any applicable Local Rules of the United States District Court for the Southern District of New York for the period during which this Agreement is in effect.
+
+13. It is understood that this Office cannot, and does not, make any promises or commitments with respect to the prosecution of JPMorgan for criminal tax violations. However, if JPMorgan fully complies with the understandings specified in this Agreement, no testimony given or other information provided by JPMorgan (or any other information directly or indirectly derived therefrom) will be used against JPMorgan in any criminal tax prosecution. In addition, the Office agrees that, if JPMorgan is in compliance with all of its obligations under this Agreement, the Office will, at the expiration of the period of deferral (including any extensions thereof), seek dismissal with prejudice of the Information filed against JPMorgan pursuant to this Agreement. Except in the event of a violation by JPMorgan of any term of this Agreement or as otherwise provided in Paragraph 14, the Office will bring no additional charges or other civil action against JPMorgan, except for criminal tax violations, relating to its conduct as described in the admitted Statement of Facts. This Agreement does not provide any protection against prosecution for any crimes except as set forth above and does not apply to any individual or entity other than JPMorgan and its affiliated entities. JPMorgan and the Office understand that the Agreement to defer prosecution of JPMorgan must be approved by the Court, in accordance with 18 U.S.C. § 3161(h)(2). Should the Court decline to approve the Agreement to defer prosecution for any reason: (a) both the Office and JPMorgan are released from any obligation imposed upon them by this Agreement; (b) this Agreement shall be null and void, except for the tolling provision set forth in Paragraph 14, below; and (c) if it has already been transferred to the United States pursuant to Paragraph 5, above, the Stipulated Forfeiture Amount shall be returned to JPMorgan.
+
+14. It is understood that should the Office in its sole discretion determine that JPMorgan: (a) has knowingly given false, incomplete or misleading information either during the term of this Agreement or in connection with the Office's investigation of the conduct described in the Information or Statement of Facts; (b) committed any crime under the federal laws of the United States subsequent to the execution of this Agreement; or (c) otherwise violated any provision of this Agreement, JPMorgan shall, in the Office's sole discretion, thereafter be subject to prosecution for any federal criminal violation, or suit for any civil cause of action, of which
+
+the Office has knowledge, including but not limited to a prosecution or civil action based on the Information, the Statement of Facts, the conduct described therein, or perjury and obstruction of justice. Any such prosecution or civil action may be premised on any information provided by or on behalf of JPMorgan to the Office, the FBI, or the United States Department of the Treasury, Office of the Comptroller of the Currency ("OCC") at any time, with the exception of any information provided solely to the OCC and/or other regulators pursuant to Title 12, United States Code, Section 1828(x). In any prosecution or civil action based on the Information, the Statement of Facts, or the conduct described therein, it is understood that: (a) no charge would be time-barred provided that such prosecution is brought within the applicable statute of limitations period (subject to any prior tolling agreements between the Office and JPMorgan), and excluding the period from the execution of this Agreement until its termination; and (b) JPMorgan agrees to toll, and exclude from any calculation of time, the running of the statute of limitations for the length of this Agreement starting from the date of the execution of this Agreement and including any extension of the period of deferral of prosecution pursuant to Paragraph 16 below. By this Agreement, JPMorgan expressly intends to and hereby does waive its rights in the foregoing respects, including any right to make a claim premised on the statute of limitations, as well as any constitutional, statutory, or other claim concerning pre-indictment delay. Such waivers are knowing, voluntary, and in express reliance on the advice of JPMorgan's counsel.
+
+15. It is further agreed that in the event that the Office, in its sole discretion, determines that JPMorgan has violated any provision of this Agreement, including JPMorgan's failure to meet its obligations under this Agreement: (a) all statements made or acknowledged by or on behalf of JPMorgan to the Office and the FBI or the OCC, including but not limited to the Statement of Facts, or any testimony given by JPMorgan or by any agent of JPMorgan before a grand jury, or other tribunal, whether before or after the date of this Agreement, or any leads from such statements or testimony, shall be admissible in evidence in any and all criminal proceedings hereinafter brought by the Office against JPMorgan; and (b) JPMorgan shall not assert any claim under the United States Constitution, Rule 11(f) of the Federal Rules of Criminal Procedure, Rule 410 of the Federal Rules of Evidence, or any other federal rule, that such statements made by or on behalf of JPMorgan before or after the date of this Agreement, or any leads derived therefrom, should be suppressed or otherwise excluded from evidence. It is the intent of this Agreement to waive any and all rights in the foregoing respects, provided, however, that this Paragraph shall not apply to any information provided solely to the OCC and/or other regulators pursuant to Title 12, United States Code, Section 1828(x).
+
+16. JPMorgan agrees that, in the event that the Office determines during the period of deferral of prosecution described in Paragraph 12 above (or any extensions thereof) that JPMorgan has violated any provision of this Agreement, an extension of the period of deferral of prosecution may be imposed in the sole discretion of the Office, up to an additional one year, but in no event shall the total term of the deferral-of-prosecution period of this Agreement exceed three (3) years.
+
+17. JPMorgan, having truthfully admitted to the facts in the Statement of Facts, agrees that it shall not, through its attorneys, agents, or employees, make any statement, in litigation or otherwise, contradicting the Statement of Facts or its representations in this Agreement. Consistent with this provision, JPMorgan may raise defenses and/or assert affirmative claims in any civil proceedings brought by private parties as long as doing so does not contradict the Statement of Facts or such representations. Any such contradictory statement by JPMorgan, its present or future attorneys, agents, or employees shall constitute a violation of this Agreement and JPMorgan thereafter shall be subject to prosecution as specified in Paragraphs 14 through 15, above, or the deferral-of-prosecution period shall be extended pursuant to Paragraph 16, above. The decision as to whether any such contradictory statement will be imputed to JPMorgan for the purpose of determining whether JPMorgan has violated this Agreement shall be within the sole discretion of the Office. Upon the Office's notifying JPMorgan of any such contradictory statement, JPMorgan may avoid a finding of violation of this Agreement by repudiating such statement both to the recipient of such statement and to the Office within forty-eight (48) hours after receipt of notice by the Office. JPMorgan consents to the public release by the Office, in its sole discretion, of any such repudiation. Nothing in this Agreement is meant to affect the obligation of JPMorgan or its officers, directors or employees to testify truthfully in any judicial proceeding.
+
+18. JPMorgan agrees that it is within the Office's sole discretion to choose, in the event of a violation, the remedies contained in Paragraphs 14 and 15, above, or instead to choose to extend the period of deferral of prosecution pursuant to Paragraph 16, provided, however, that if JPMorgan's violation of this Agreement is limited to an untimely payment of the Stipulated Forfeiture Amount, the Office may elect instead to choose the additional financial penalties set forth in Paragraph 5, above. JPMorgan understands and agrees that the exercise of the Office's discretion under this Agreement is unreviewable by any court. Should the Office determine that JPMorgan has violated this Agreement, the Office shall provide notice to JPMorgan of that determination prior to exercising any of those remedies and provide JPMorgan with an opportunity to make a presentation to the Office to demonstrate that no violation occurred, or, to the extent applicable, that the violation should not result in the exercise of any of those remedies, including because the violation has been cured by JPMorgan.
+
+#### **JPMorgan's BSA/AML Compliance Program**
+
+19. JPMorgan shall continue its ongoing effort to implement and maintain an effective BSA/AML compliance program in accordance with the requirements of the BSA and the directives and orders of any United States regulator of JPMorgan or its affiliates, including without limitation the OCC and Federal Reserve Board, as set forth in their respective Consent Cease and Desist Orders, dated January 14, 2013 ("Consent Orders"). The Office acknowledges that, pursuant to the Consent Orders, JPMorgan has implemented and is continuing to implement significant remedial changes to its BSA/AML compliance program, prior to the entry of this Agreement. It is understood that a violation of the BSA or the Consent Orders arising from conduct occurring prior to the date of execution of this Agreement, including with respect to any
+
+SAR-filing obligation, will not constitute a breach of JPMorgan's obligations pursuant to this Agreement. However, there shall be no limitation on the ability of the Office to investigate or prosecute such violations and/or conduct in accordance with the applicable law and the other terms of this Agreement, including Paragraph 13 hereof.
+
+### **Review of JPMorgan's BSA/AML Compliance Program**
+
+20. For the duration of the Agreement, JPMorgan shall provide the Office with quarterly reports ("Quarterly Reports") describing the status of JPMorgan's implementation of the remedial changes to its BSA/AML compliance program required by the Consent Orders. The Quarterly Reports shall identify any violations of the BSA that have come to the attention of JPMorgan's United States legal and compliance personnel during this reporting period.
+
+21. For the duration of the Agreement, the Office, as it deems necessary and upon request to JPMorgan, shall: (a) be provided by JPMorgan with access to any and all non-privileged books, records, accounts, correspondence, files, and any and all other documents or electronic records, including e-mails, of JPMorgan and its representatives, agents, affiliates, and employees, relating to any matters described or identified in the Quarterly Reports; and (b) have the right to interview any officer, employee, agent, consultant, or representative of JPMorgan concerning any non-privileged matter described or identified in the Quarterly Reports.
+
+22. It is understood that JPMorgan shall promptly notify the Office of (a) any deficiencies, failings, or matters requiring attention with respect to JPMorgan's BSA/AML compliance program identified by any United States regulatory authority within 10 business days of any such regulatory notice; and (b) any steps taken or planned to be taken by JPMorgan to address the identified deficiency, failing, or matter requiring attention. The Office may, in its sole discretion, direct JPMorgan to provide other reports about its BSA/AML compliance program as warranted.
+
+### **Limits of this Agreement**
+
+23. It is understood that this Agreement is binding on the Office but does not bind any other Federal agencies, any state or local law enforcement agencies, any licensing authorities, or any regulatory authorities. However, if requested by JPMorgan or its attorneys, the Office will bring to the attention of any such agencies, including but not limited to any regulators, as applicable, this Agreement, the cooperation of JPMorgan, and JPMorgan's compliance with its obligations under this Agreement.
+
+### **Public Filing**
+
+24. JPMorgan and the Office agree that, upon the submission of this Agreement (including the Statement of Facts and other attachments hereto) to the Court, the Agreement (and its attachments) shall be filed publicly in the proceedings in the United States District Court for the Southern District of New York.
+
+25. The parties understand that this Agreement reflects the unique facts of this case and is not intended as precedent for other cases.
+
+# Execution in Counterparts
+
+26. This Agreement may be executed in one or more counterparts, each of which shall be considered effective as an original signature. Further, all facsimile and digital images of signatures shall be treated as originals for all purposes.
+
+[REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK]
+
+## Integration Clause
+
+27. This Agreement sets forth all the terms of the Deferred Prosecution Agreement between JPMorgan and the Office. No modifications or additions to this Agreement shall be valid unless they are in writing and signed by the Office, JPMorgan's attorneys, and a duly authorized representative ofJPMorgan.
+
+Dated: New York. New York January 6.2014
+
+Sincerely.
+
+PREET BHARARA United States Attorney Southern Di f New York
+
+By: A' D MATTHEW L. Assistant Unite States Attorneys
+
+Accepted and agreed to:
+
+PHEN M. CUTLER General Counsel, JPMoigan Chase Bank. N.A.
+
+WREN L. REISNF.R Chief. Criminal Division r
+
+SE, ESQ. rgan Chase Bank. N.A. D tc
+
+Date
+
+# Exhibit A
+
+## JIPMORCAN CHASE BANK, N.A. RESOLUTIONS OF THE BOARD OF DIRECTORS
+
+The following resolutions were duly adopted at a meeting of the Board of Directors of JPMorgan Chase Bank, N.A. ("JPMCB") held on January 3.2014:
+
+WHEREAS, JPMCB has been engaged in discussions with the U.S. Attorney's Office for the Southern District of New York (the "U.S. Attorney's Office") in connection with an investigation (the "Investigation") being conducted by the U.S. Attorney's Office of JPMCB's relationship with Bernard L. Madoff Investment Securities LLC; and
+
+WHEREAS, the Board of Directors of JPMCB has determined that it is in the best interests of JPMCB to enter into a Deferred Prosecution Agreement (the "DPA"), which would resolve the U.S. Attorney's Office's Investigation;
+
+RESOLVED that the Board of Directors of JPMCB consents to the resolution of the discussions with the U.S. Attorney's Office by entering into the DPA in substantially the same form as reviewed by the Board of Directors of JPMCB on January 3, 2014; and
+
+RESOLVED that the Board of Directors of JPMCB authorizes Stephen M. A General Counsel, and outside counsel representing JPMCB from Wachtel!, Lipton, & Katz to execute the DPA on behalf of JPMCB and for them, and for other appropriate officers of JPMCB, to take any and all other actions as may be necessary or appropriate, and to approve the fonns, terms, or provisions of any agreements or other documents as may be necessary or appropriate to carry out and effectuate the purpose and intent of the foregoing.
+
+tephen M. Cutler
+
+General Counsel, JPMorgan Chase Bank, N.A.
+
+# Exhibit B
+
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+UNITED STATES OF AMERICA,
+
+# INFORMATION
+
+14 Cr.
+
+JPMORGAN CHASE BANK, N.A.,
+
+Defendant.
+
+# COUNT ONE
+
+## (Violation of the Bank Secrecy Act: Failure to Maintain an Effective Anti-Money Laundering Program)
+
+The United States Attorney charges:
+
+## Background
+
+- 1. At all times relevant to this Information, Bernard L. Medoff Investment Securities LLC, and its predecessor, Bernard L. Medoff Investment Securities (collectively and separately, "Madoff Securities"), had its principal place of business in New York, New York. Medoff Securities operated three principal lines of business: market making, proprietary trading, and
+- investment advisory. Medoff Securities was registered with the United States Securities and Exchange Commission ("SEC") as a broker-dealer since in or about 1960 and as an investment adviser since in or about August 2006. Bernard L. Madoff ("Medoff") was the founder of Medoff Securities and its sole owner.
+- 2. JPMorgan Chase & Co. ("JPMC" or the "Bank") is a financial holding company incorporated under Delaware law in 1968, with its principal place of business in New York, New York. JPMC operates four lines of business, including the Corporate and Investment Bank, Asset Management, Commercial Banking, and Consumer and Community Banking.
+
+3. JPMORGAN CHASE BANK, N.A., the defendant, was at all relevant times the principal banking subsidiary of JPMC. JPMORGAN CHASE BANK, N.A., provides banking services throughout the United States, and is subject to oversight and regulation by the United States Department of the "treasury, Office of the Comptroller of the Currency (the "OCC").
+
+## The Bank Secrecy Act
+
+4. The Currency and Foreign Transactions Reporting Act of 1970 (commonly known as the Bank Secrecy Act, or "BSA"), 31 U.S.C. § 5311, et seq., and its implementing regulations require domestic banks and certain other financial institutions to establish and maintain programs designed to detect and report suspicious activity, and to maintain certain related records "where they have a high degree of usefulness in criminal, tax, or regulatory investigations or proceedings." 31 U.S.C. § 5311.
+
+5. Among other things, the BSA requires that financial institutions "maintain appropriate procedures to ensure compliance with (the BSA] and regulations prescribed under [the BSA] or to guard against money laundering." 31 U.S.C. § 5318(aX2). Pursuant to 31 U.S.C. § 5318(h)(1) and 12 C.F.R. § 21.21, JPMORGAN CHASE BANK, N.A., the defendant, was required to establish and maintain an anti-money laundering ("AML") compliance program that, at a minimum:
+
+- a. provided internal policies, procedures, and controls designed to guard against money laundering;
+- b. provided for a compliance officer to coordinate and monitor day-to-day compliance with the BSA and AML requirements;
+- c. provided for an ongoing employee training program; and
+- d. provided for independent testing for compliance conducted by bank personnel or an outside party.
+
+6. In addition, the BSA requires financial institutions to "report any suspicious transaction relevant to a possible violation of law or regulation." 31 U.S.C. § 5318(g)(1). Pursuant to 31 U.S.C. § 53I8(g) and 12 C.F.R. § 21.11, a financial institution is required to file a Suspicious Activity Report ("SAR') when it "knows, suspects, or has reason to suspect" that a transaction, among other things, involves funds derived from illegal activities or has no apparent business or lawful purpose.
+
+# The Madoff Securities Ponzi Scheme
+
+7. For more than three decades, the Madoff Securities investment advisory business was a massive, multi-billion dollar Ponzi scheme. From at least as early as the 1970s through Madoff s arrest on December 11, 2008, Madoff and his co-conspirators fraudulently promised investors in Madoff Securities that their money would be invested in stocks, options, and other securities of well-known corporations. Contrary to these representations, investor money was in fact virtually never invested as promised. Instead, the Madoff Securities investment advisory business operated as a massive Ponzi scheme in which some investors were paid with money "invested" by different investors, and other proceeds were used to personally benefit Madoff and the people around him. At the time of its collapse in December 2008, Madoff Securities maintained more than 4,000 investment advisory client accounts, which purported to have a combined balance of approximately \$65 billion. In fact, Madoff Securities had only approximately \$300 million in assets at the time.
+
+8. From in or about October 1986 through Madoffs arrest on December 11, 2008, the Madoff Ponzi scheme was conducted almost exclusively through a demand deposit account and other linked cash and brokerage accounts held at JPMORGAN CHASE BANK, N.A., the defendant (collectively, the "703 Account"). During that time period, virtually all client
+
+investments were deposited into the primary Madoff Securities account at JPMORGAN CHASE BANK, N.A., and virtually all client "redemptions" were paid from a linked disbursement account, also held by Madoff Securities at JPMORGAN CHASE BANK, N.A.
+
+## October 2008: JPMC's Suspicions That Madoff's Returns Were Too Good To Be True
+
+9. Since 2006, the Bank's London-based Equity Exotics Desk, which specialized in creating complex derivatives based on the performance of certain investment funds, had issued structured products linked to the returns of "feeder" funds that were invested in Madoff Securities. As a hedge for its issuance of these derivative products, JPMC made certain proprietary investments tied to the returns of Madoff Securities. On October 16, 2008, an analyst on the Equity Exotics Desk, wrote a lengthy c-mail to the head of the desk and others about Madoff Securities (the "October 16 Memo"). The October 16 Memo, among other things, described JPMC's inability to validate Madoff's trading activity or even custody of assets; questioned Madoffs "odd choice" of a small, unknown accounting firm; and reported that JPMC "seem[ed] to be relying on Madoff s integrity" with little to verify that such reliance was wellplaced. The October 16 Memo ended with the observation that: "[t]here are various elements in the story that could make us nervous," including the "feeder" funds managers' "apparent fear of Madoff, where no one dares to ask any serious questions as long as the performance is good."
+
+10. On or about October 29, 2008, JPMORGAN CHASE BANK, N.A., the defendant, filed a report with the United Kingdom Serious Organised Crime Agency ("SOCA") pursuant to the U.K. Proceeds of Crime Act. In that report, which identified Madoff Securities as its "Main Subject — Suspect," JPMORGAN CHASE BANK, N.A., reported that, among other things, "the investment performance achieved by [the Madoff Securities] funds . . . is so consistently and significantly ahead of its peers year-on-year, even in the prevailing market
+
+conditions, as to appear too good to be true — meaning that it probably is." JPMORGAN CHASE BANK, N.A., reported that, "[a]s a result," it had submitted redemption requests for more than \$300 million of its own funds, which were invested in Madoff Securities "feeder" funds.
+
+11. JPMORGAN CHASE BANK, N.A., the defendant, failed to file a SAR in the United States concerning Madoff Securities or Madoff. The concerns raised in the October 16 Memo were never communicated to anti-money laundering compliance personnel in the United States, and there was no meaningful effort by the Bank to examine or investigate the Madoff Securities banking relationship with JPMC, including the transaction activity in the 703 Account.
+
+12. Prior to Madoff's arrest on December 11, 2008, JPMORGAN CHASE BANK, N.A., the defendant, lacked effective policies, procedures, or controls designed to reasonably ensure that information — such as the information culminating in the October 2008 report to SOCA — obtained in the course of JPMC's other lines of business, was communicated to antimoney laundering compliance personnel based in the United States. In addition, JPMORGAN CHASE BANK, N.A., lacked effective policies, procedures, or controls designed to reasonably ensure that information about United States-based clients, obtained by JPMC in its business abroad, was communicated to anti-money laundering compliance personnel based in the United States. These systemic deficiencies reflected a failure to maintain adequate policies, procedures, and controls to ensure compliance with the BSA and regulations prescribed thereunder and to guard against money laundering.
+
+# Statutory Allegation
+
+13. In or about 2008, in the Southern District of New York and elsewhere, JPMORGAN CHASE BANK, N.A., the defendant, did willfully fail to establish an adequate anti-money laundering program, including, at a minimum, (a) the development of internal policies, procedures, and controls designed to guard against money laundering; (b) the designation of a compliance officer to coordinate and monitor day-to-day compliance with the Bank Secrecy Act and anti-money laundering requirements; (c) the establishment of an ongoing employee training program; and (d) the implementation of independent testing for compliance conducted by bank personnel or an outside party, to wit, JPMORGAN CHASE BANK, N.A., failed to enact adequate policies, procedures, and controls to ensure that information about the Bank's clients obtained through activities in and concerning JPMC's other lines of business was shared with compliance and anti-money laundering personnel, and to ensure that information about the Bank's clients obtained outside the United States was shared with United States compliance and anti-money laundering personnel.
+
+> (Title 31, United States Code, Sections 5318(h) and 5322(a); and Title 12, Code of Federal Regulations, Section 21.21.)
+
+# COUNT TWO
+
+## (Violation of the Bank Secrecy Act: Failure to File a Suspicious Activity Report)
+
+The United States Attorney further charges:
+
+14. The allegations contained in paragraphs 1 through 12 above are hereby repeated, realleged and incorporated by reference as if fully set forth herein.
+
+# Statutory Allegation
+
+15. In or about October 2008, in the Southern District of New York and elsewhere, JPMORGAN CHASE BANK, N.A., the defendant, did willfully fail to report suspicious transactions relevant to a possible violation of law or regulations, as required by the Secretary of the Treasury, to wit, JPMORGAN CHASE BANK, N.A., the defendant, failed to file a Suspicious Activity Report in the United States with respect to transactions in bank accounts maintained by Madoff Securities.
+
+> (Title 31, United States Code, Sections 5318(g) and 5322(a); and Title 12, Code of Federal Regulations, Section 21.11.)
+
+> > At I%. PREET BHARARA United States Attorney
+
+Form No. USA-33s-274 (Ed. 9-25-58)
+
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+## UNITED STATES OF AMERICA
+
+- v -
+
+JPMORGAN CHASE BANK, N.A.,
+
+Defendant.
+
+## INFORMATION
+
+14 Cr.
+
+31 U.S.C. §§ 5318(g), 5318(h), 5322(a); Title 17, Code of Federal Regulations, Sections 21.11 and 21.21.
+
+PREET BHARARA United States Attorney.
+
+# Exhibit C
+
+## STATEMENT OF FACTS
+
+The following Statement of Facts is incorporated by reference as part of the Deferred Prosecution Agreement (the "Agreement") between the United States Attorney's Office for the Southern District of New York ("USAO") and JPMorgan Chase Bank, N.A., a subsidiary of JPMorgan Chase & Co. As used herein, and unless otherwise specified, "JPMC" refers collectively to JPMorgan Chase & Co., its subsidiaries, and their predecessors in interest. The parties agree and stipulate that the following information is true and accurate:
+
+### Bank Structure
+
+1. 1. JPMorgan Chase & Co., a financial holding company incorporated under Delaware law in 1968, is a leading global financial services firm and the largest banking institution in the United States. JPMorgan Chase & Co.'s principal bank subsidiary is JPMorgan Chase Bank, N.A., which provides banking services throughout the United States and is regulated chiefly by the United States Department of Treasury, Office of the Comptroller of the Currency (the "OCC").
+2. 2. JPMC operates four lines of business: the Corporate and Investment Bank, Asset Management, Commercial Banking, and Consumer & Community Banking. The Corporate and Investment Bank offers global investment banking services through various subsidiaries and affiliates of JPMC, including JPMorgan Chase Bank, N.A., JPMorgan Securities LLC (the United States broker-dealer for JPMC, registered with the Securities & Exchange Commission), and JPMorgan Securities plc (in the United Kingdom).
+
+### The Bank Secrecy Act's Requirements
+
+1. 3. The Currency and Foreign Transactions Reporting Act of 1970 (commonly known as the Bank Secrecy Act, or "BSA"), Title 31, United States Code, Section 5311, *et seq.*, requires financial institutions – including JPMorgan Chase & Co., JPMorgan Chase Bank, N.A., and other JPMC affiliates – to take certain steps to protect against the financial institution being used by criminals to commit crimes and launder money.
+2. 4. The BSA requires financial institutions to establish and maintain effective anti-money laundering ("AML") compliance programs that, at a minimum and among other things, provide for: (a) internal policies, procedures, and controls designed to guard against money laundering; (b) an individual or individuals to coordinate and monitor day-to-day compliance with BSA and AML requirements; (c) an ongoing employee training program; and (d) an independent audit function to test compliance programs. 31 U.S.C. § 5318(h).
+3. 5. The BSA and regulations thereunder also require financial institutions to report "suspicious transaction[s] relevant to a possible violation of law or regulation." 31 U.S.C. § 5318(g)(1). BSA regulations provide that a transaction is reportable if it is "conducted or attempted by, at, or through the bank" and where "the bank knows, suspects, or has reason to suspect that . . . [t]he transaction involves funds derived from illegal activities" or that the "transaction has no business or apparent lawful purpose." 31
+
+C.F.R. § 1020.320(a)(2). A separate BSA regulation provides that a bank must file a Suspicious Activity Report ("SAR") where the bank "detects any known or suspected Federal criminal violation, or pattern of criminal violations . . . aggregating \$5,000 or more in funds or other assets . . . where the bank believes that . . . it was used to facilitate a criminal transaction, and the bank has a substantial basis for identifying a possible suspect or group of suspects." 12 C.F.R. § 21.11(c)(2). If the transactions total more than \$25,000, then a bank must file a report even if it cannot identify a suspect. 12 C.F.R. § 21.11(c)(3). Financial institutions satisfy their obligation to report such a transaction by filing a SAR with the Financial Crimes Enforcement Network ("FinCEN"), a part of the United States Department of Treasury. 31 C.F.R. § 1020.320(a)(1).
+
+1. 6. At all relevant times, JPMC designated an executive located in New York, New York (the "JPMC BSA Officer") as the head of JPMC's AML program and the individual ultimately responsible for ensuring JPMC's ongoing compliance with its BSA obligations, including the filing of SARs when required. JPMC's AML program included individuals based in the United States and other countries responsible for filing suspicious activity reports in the relevant jurisdictions.
+
+An Overview Of JPMC's Banking Relationship With Madoff
+
+1. 7. Bernard L. Madoff ("Madoff") ran the largest known Ponzi scheme in history through Bernard L. Madoff Investment Securities LLC and its predecessors and affiliates (collectively, "Madoff Securities"). At the time of its collapse in December 2008, Madoff Securities maintained more than 4,000 investment advisory client accounts, which purported to have a combined balance of approximately \$65 billion under management. In fact, Madoff Securities had only approximately \$300 million in assets at the time, including approximately \$234 million in cash and cash equivalents held by Madoff Securities in JPMC bank accounts.
+2. 8. Madoff Securities maintained a continuous banking relationship with JPMC and its predecessor institutions, including Manufacturer's Hanover Trust, Chemical Bank and The Chase Manhattan Bank, between at least approximately 1986 and Madoff's arrest in December 2008.
+3. 9. Madoff Securities held a series of linked direct deposit and custodial accounts at JPMC organized under the umbrella of a centralized "concentration account," number 140-081703 (collectively, the "703 Account"). The 703 Account was the bank account that received and remitted, through a linked disbursement account, the overwhelming majority of funds that Madoff's victims "invested" with Madoff Securities. In addition, Madoff Securities maintained linked accounts at JPMC through which Madoff held the funds obtained through his Ponzi scheme in, among other things, government securities and commercial paper.
+4. 10. Between approximately 1986 and Madoff's arrest in December 2008, the 703 Account received deposits and transfers of approximately \$150 billion, almost exclusively from Madoff Securities investors. The 703 Account was not a securities settlement account
+
+and the funds deposited by Madoff's victims into the 703 Account were not used for the purchase and sale of stocks, corporate bonds, or options, as Madoff had promised his customers he would invest their money. Nor were the funds deposited into the 703 Account transferred to other broker-dealers for the purchase and sale of securities.
+
+1. 11. The balance in the 703 Account generally increased over time, peaking at approximately \$5.6 billion in August 2008. Between August 2008 and Madoff's arrest on December 11, 2008, billions were transferred from the 703 Account to customers of Madoff Securities, leaving a balance of only approximately \$234 million.
+2. 12. As described herein, at various times between the late 1990s and 2008, employees of various divisions of JPMC and its predecessor entities raised questions about Madoff Securities, including questions about the validity of Madoff Securities's investment returns. At no time during this period did JPMC personnel communicate their concerns about Madoff Securities to AML personnel in the United States responsible for JPMC's banking relationship with Madoff Securities. Nor did JPMC file any SAR in the United States relating to Madoff Securities until after Madoff's arrest.
+
+JPMC's Tools For Identifying Money Laundering Among Broker/Dealer Clients
+
+1. 13. The Madoff Securities banking relationship with JPMC was handled by the JPMC Investment Bank's Broker-Dealer Banking Group (the "B/D Group"), which provided access to an array of banking services to approximately 200-250 broker-dealer clients. Each broker-dealer client had an assigned client executive (also known as a "relationship manager" or simply "banker") who was the primary point of contact for that client.
+2. 14. Each relationship manager in the B/D Group was required, pursuant to JPMC policy, to periodically certify that he had "(i) determin[ed], . . . on an ongoing basis, whether an existing . . . relationship complies with relevant legal and regulatory-based policies and meets the firm[']s corporate client standards, and (ii) [taken] appropriate action to identify, communicate and resolve any issue that may arise in the course of such determinations." Client sponsorship also expressly "require[d] [the banker], as a Senior Officer of JPMorgan, to recertify on a periodic basis . . . that the necessary due diligence has been performed [and] that the client and its subsidiaries continue to meet the JPMC corporate client standards in relation to any potential reputation risk."
+3. 15. Following a restructuring of the B/D Group in or about 2007, the JPMC employees providing various services to B/D Group clients, such as credit or loan officers, were moved out of the B/D Group and instead reassigned to other parts of the Bank. As a result, client financial statements, regulatory filings, credit reviews, and other documents that had in the past been reviewed by the relationship manager were no longer regularly reviewed within the B/D Group, although employees in JPMC's Credit department still reviewed such documents.
+4. 16. JPMC also relied on a computerized system to comply with its AML obligations. Specifically, with respect to demand deposit accounts (*i.e.*, accounts holding client funds that can be withdrawn at any time, such as the 703 Account), JPMC employed different
+
+software tools commonly used by large financial institutions to monitor account activity. Among other things, these software tools sought to determine how an account's activity compared to "peer" accounts and whether the account in question was behaving uncharacteristically for the peer group in terms of the value of the account and the volume of transactions.
+
+1. 17. In the event that the computerized AML systems generated an "alert" for potentially irregular activity, JPMC policy provided that an AML investigations team within JPMC's compliance department would investigate the alert and take appropriate action, which could include contacting business people at the bank, if any action was required. The AML alert process operated independently of the client sponsorship process, and AML officers monitoring the alerts did not have immediate access to computerized information providing the identity of the relationship manager in the event that the AML officer deemed it appropriate to contact the relationship manager to determine whether the alerted activity was consistent with the relationship manager's knowledge of the banking relationship.
+2. 18. In addition, the AML investigations teams monitoring the alerts were expected to have access to the appropriate records about the client, including so-called "know-your-customer" material (often referred to as "KYC material") that JPMC maintained in connection with its BSA obligations and pursuant to bank policy. The computerized AML system provided a means for AML investigators to review centrally maintained electronic copies of KYC materials. However, JPMC's efforts to electronically store KYC materials were behind schedule and, accordingly, as set forth herein, on some occasions AML investigations teams responding to alerts were unable to access the computerized KYC material on the client as part of their investigation.
+
+The Use of JPMC's AML Tools in Connection With The Madoff Securities Accounts
+
+1. 19. With respect to JPMC's requirement that a client relationship manager certify that the client relationship complied with all "legal and regulatory-based policies," a JPMC banker ("Madoff Banker 1") signed the periodic certifications beginning in or about the mid-1990s through his retirement in early 2008, when the client relationship was assigned to a second individual ("Madoff Banker 2"). In March 2009 – three months after Madoff's arrest – Madoff Banker 2 received a form letter from JPMC's Compliance function asking him to certify the client relationship again.
+2. 20. During his tenure at JPMC, Madoff Banker 1 periodically visited Madoff's offices and obtained financial documents from Madoff Securities in connection with periodic loans JPMC made to the firm. Despite those visits and financial documents, and despite the fact that Madoff Banker 1 was aware of Madoff's standing in the industry, Madoff Banker 1 had a limited and inaccurate understanding of both Madoff's business, as well as the purpose and balance of the demand deposit accounts maintained by Madoff Securities at JPMC. Madoff Banker 1 believed that the 703 Account was primarily a Madoff Securities broker-dealer operating account, used to pay for rent and other routine expenses. Madoff Banker 1 also believed that the average balance in Madoff Securities' demand deposit account was "probably [in the] tens of millions." He did not understand
+
+that the 703 Account was, in fact, the account used by Madoff's investment advisory business, and achieved balances of well more than \$1 billion beginning in approximately 2005, and up to approximately \$5.6 billion by 2008. Madoff Banker 1 stated that he recertified his sponsorship of the Madoff relationship each year because no adverse information about Madoff Securities was brought to his attention.
+
+1. 21. With respect to the computerized AML system, on two occasions the system generated "alerts" with respect to potentially suspicious activity in Madoff Securities. In January 2007, the 703 Account "alerted" because of unusual third party wire activity. On the day of the alert, January 3, 2007, the 703 Account received \$757.2 million in customer wires and transfers, 27 times the average daily value of incoming wires and transfers over the prior 90 days of activity, virtually all of which came from Madoff "feeder funds" that offered to invest funds from their own customers in Madoff Securities. In July 2008, the system alerted due to activity associated with Treasury bond redemptions. In both cases, the AML investigators closed the alerts with a notation that the transactions did not appear to be unusual for the account in comparison to the account's prior activity. In both cases, prior to closing the alerts, the investigators attempted to review the KYC file for Madoff Securities but, upon receiving error messages to the effect that no file was available, did not conduct further investigation into the business of Madoff Securities beyond a review of the company's website.
+
+Transactions In the Madoff Securities Account Identified By JPMC Private Bank Predecessors
+
+1. 22. Beginning in the mid-1990s, employees in the Private Bank for Chemical Bank, a predecessor of JPMC, identified a series of transactions between the account of a Private Bank client (the "Private Bank Client") and accounts held by Madoff Securities, including the 703 Account.<sup>1</sup> As one of the bank's largest individual clients, with a portfolio valued (as of the mid-1990s) at approximately \$2.3 billion, the Private Bank Client was highly valued by JPMC and its predecessors and was provided with his own office within JPMC's offices. In addition, the Bank's Global Trust & Fiduciary Services business line served (along with Bernard L. Madoff) as co-executor and co-trustee of the Private Bank Client's will, and stood to earn approximately \$15 million in fee income upon his death.
+2. 23. The transactions between Madoff and the Private Bank Client consisted of "round-trip" transactions which would typically begin with Madoff writing checks from an account at another bank ("Madoff Bank 2") to one of the Private Bank Client's accounts at JPMC and its predecessors. Later the same day, Madoff would transfer money from his 703 Account to his account at Madoff Bank 2 to cover the earlier check from Madoff Bank 2
+
+---
+
+<sup>1</sup> In July 1996, Chemical Bank acquired The Chase Manhattan Bank, N.A. by merger and began offering banking services, including private banking, under the name The Chase Manhattan Bank. In November 2001, The Chase Manhattan Bank acquired ██████████ Guaranty Trust Company of New York by merger and began offering banking services, including private banking, under the name JPMorgan Chase Bank. The Private Bank Client maintained an account at the JPMC Private Bank through his death in September 2005.
+
+to the Private Bank Client at JPMC. And, in the final leg of the transaction, as known to JPMC, the Private Bank Client would transfer funds from his JPMC account to the 703 Account in an amount sufficient to cover the original check he had received from Madoff at Madoff Bank 2. These round-trip transactions occurred on a virtually daily basis for a period of years, and were each in the amount of tens of millions of dollars. Because of the delay between when the transactions were credited and when they were cleared (referred to as the “float”), the effect of these transactions was to make Madoff’s balances at JPMC appear larger than they otherwise were, resulting in inflated interest payments to Madoff by JPMC.
+
+1. 24. In or around November 1994, an employee of the JPMC Private Bank drafted a memo stating that “the daily cost associated with” the overdrafts from the transactions is “outrageous,” and documenting calls on November 29, 1994, in which the employee informed both Madoff and the Private Bank client that JPMC was aware of the activity and the fact that it allowed Madoff to earn interest on uncleared funds. According to the memo, the Private Bank Client responded that “if Bernie is using the float, it is fine with me, he makes a lot of money for my account.”
+2. 25. In or about 1996, personnel from Madoff Bank 2 investigated the round-trip transactions between Madoff and the Private Bank Client. As a result of that investigation, which included meeting with representatives of Madoff Securities, Madoff Bank 2 concluded that there was no legitimate business purpose for these transactions, which appeared to be a “check kiting” scheme, and terminated its banking relationship with Madoff Securities. According to personnel from Madoff Bank 2, JPMC was notified of Madoff Bank 2’s closure of Madoff’s bank account. In addition, although unknown to JPMC at the time, Madoff Bank 2 filed a SAR in or about 1996 identifying both Madoff Securities and the Private Bank Client as being involved in suspicious transactions at Madoff Bank 2 and JPMC “for which there was no apparent business purpose.”
+3. 26. JPMC Private Bank did not file a suspicious activity report relating to the transaction activity between the Private Bank Client and Madoff Securities, or terminate its banking relationship with Madoff, or direct the parties to cease such transactions. JPMC allowed the Private Bank Client transactions to continue, although JPMC did require the Private Bank Client to reimburse JPMC for the interest payments that these transactions had cost the bank.
+4. 27. After Madoff Bank 2 closed the Madoff Securities account in or about 1996, the Private Bank Client and Madoff Securities continued to engage in round-trip transactions, the sizes of which increased, entirely through JPMC accounts. In December 2001, the Private Bank Client engaged in approximately \$6.8 billion worth of transactions with Madoff Securities — all between the Private Bank Client’s accounts at JPMC and the Madoff Securities 703 Account — in a series of usually \$90 million transactions. These transactions continued through 2003.
+5. 28. JPMC Private Bankers did not report the round-trip transactions between the Private Bank Client and Madoff Securities to JPMC AML personnel. After Madoff’s arrest in
+
+2008, JPMC AML personnel reviewed the activity and filed a SAR concerning the above transactions.
+
+Questions About Madoff Securities's Investment Returns From JPMC's Private Bank
+
+1. 29. In or about 1993, the Private Bank Client requested that a senior investment officer (the "Senior Investment Officer") of the Private Bank of Chemical Bank, a predecessor of JPMC, meet with Madoff, so that he (the Private Bank Client) could better understand how Madoff regularly generated consistent returns. Along with a quantitative analyst (the "Analyst"), the Senior Investment Officer met with Madoff. A memorandum from around the time of the visit reports that the Senior Investment Officer was "very comfortable" with Madoff, "his operation" and "the conservative, risk-averse investment approach" for the Private Bank Client, and that the Analyst said "it is quite possible for top-notch investment advisors to make 20-30% annual returns through such short-term programs." However, the Senior Investment Officer later explained that he and the Analyst could not understand how Madoff was able to generate such consistent quarterly returns for the Private Bank Client despite historic volatility in the market, and therefore concluded that Madoff "might also have been smoothing out the returns" by sharing trading spreads and profits from the Madoff Securities market-making business with the Private Bank Client.
+2. 30. In or about 1998, the Private Bank conducted a review of Madoff Securities because it had been extending credit to the Private Bank Client to invest in Madoff Securities. The review reflected that, according to Madoff Securities account statements, the Private Bank Client's reported investments, the substantial majority of which were invested through Madoff Securities, had increased from \$183 million at the end of 1986 to \$1.7 billion in early 1998 – an increase of 830 percent in 12 years. The Private Bank also learned that Madoff reported consistently positive returns for the Private Bank Client at all times, including through the October 1987 ██████████ market crash and subsequent market corrections.
+3. 31. In late 2007, JPMC Private Bank personnel also conducted due diligence on Madoff Securities because there was sufficient interest in Madoff among the Private Bank's clients such that JPMC considered putting Madoff Securities on its own "trading platform" – that is, to put some of the money that the Private Bank invested on behalf of its clients into Madoff Securities. However, the JPMC Private Bank was told that Madoff would be unwilling to meet with JPMC in connection with its due diligence efforts. The JPMC Private Bank ended the due diligence process and did not place Madoff Securities on its trading platform. After Madoff's arrest, the Chief Investment Officer of the Private Bank wrote to Private Bank customers that "we did not do business with the Madoff funds, having never been able to reverse engineer how they made the money – the numbers didn't add up . . ." JPMC Private Bank personnel did not provide this information to JPMC AML personnel.
+
+Questions About Madoff Securities's Investment Returns By A JPMC  
+Investment Fund
+
+32. Chase Alternative Asset Management ("CAAM") – the JPMC fund of funds open to institutional investors, and which was part of the Asset Management line of business – also considered placing Madoff Securities on its platform in the late 1990s and again in or about 2007. In connection with reviewing Madoff's reported returns in the late 1990s, one CAAM fund manager commented on approximately December 10, 1998 that Madoff Securities returns were "possibly too good to be true," and that there were "too many red flags" to proceed with further due diligence." In 2007, JPMC's fund of funds again considered a Madoff investment, and also discontinued the due diligence early on because the first stages of the process provided "little additional insight as to the source of the [Madoff Securities] returns" and because JPMC learned that Madoff would not meet with JPMC personnel to answer their questions. In neither the late 1990s nor 2007 did JPMC fund managers provide this information to JPMC AML personnel.
+
+JPMC's Issuance Of Madoff Derivative Products
+
+33. Beginning in approximately the Spring of 2006, JPMC invested approximately \$343 million of the Bank's own money in Madoff "feeder funds" – funds that sent investor money to Madoff Securities – as a hedge for structured products issued by JPMC's investment bank. Those derivative products were issued by JPMC in London in 2006 and 2007 through JPMC's Equity Exotics Desk, a group that specialized in creating complex derivatives based on the performance of certain investment funds. The purpose of the products was to provide investors with "synthetic exposure" to hedge funds or other equities without the investor making a direct investment in the fund itself.
+
+34. The Madoff-derivative products offered by JPMC, which were issued in response to demand for Madoff Securities-related investments, generally worked as follows: JPMC issued notes (which it sold through various distributors) and promised to pay note-holders a return that corresponded to the return of a particular Madoff feeder fund. In order to hedge the risk created by those notes, JPMC then invested the Bank's own capital in the feeder fund directly. JPMC's investment of its own money in the Madoff feeder funds as a hedge position would therefore in large part offset the risks associated with JPMC's obligation under the notes. In this business model, JPMC's Investment Bank profited from transaction fees associated with issuing the notes, and endeavored to minimize risk resulting from these issuances. Due to the features of the JPMC-issued notes, however, it was impossible for JPMC to eliminate all risks from its exposure to Madoff feeder funds. For example, with respect to certain notes issued by JPMC that would pay the noteholder three times the Madoff feeder fund's investment returns, JPMC would suffer no losses if the Madoff feeder fund decreased in value by less than 33%, but could suffer substantial losses if the Madoff feeder fund's value fell to zero.
+
+35. JPMC required approval from the Investment Bank's Risk function in connection with its own investments in hedge funds, including the Madoff feeder funds. Under pre-existing guidelines in place in 2007, approval for investments in so-called single name hedge funds (like Madoff Securities) was set at \$100 million in risk exposure to JPMC
+
+(meaning, the total amount JPMC could be expected to lose if JPMC's investment lost virtually all its value). Risk exposure above \$100 million required approval from senior risk executives, with the level of approval depending on the size of the propose<sup>d</sup> investment. In assessing potential transactions that required individual approval from the JPMC risk function, risk officers assessed both "market risk" (i.e., the risk associated with the investment performance of the underlying fund, assuming the fund followed its advertised strategy) and "credit risk" (t e., whether the fund could be trusted with the Bank's money). In the context of hedge fund investments, one credit risk factor in all proposed transactions was the risk that the fund manager was committing fraud. The scope of fraud risk ranged from a manager who deviated from a promised investment strategy to a manager who was reporting entirely fictitious returns.
+
+- 36. From the outset, JPMC's risk personnel recognized that there was little market risk provided that Madoff was investing client fluids in the split-strike conversion strategy that Madoff claimed he was. Accordingly, JPMC risk personnel promptly identified credit risk, and in particular the risk of fraud, as the central potential risk to JPMC. For example, in a February 1, 2006 e-mail, arisk executive evaluating the Madoff derivatives proposal commented, "[I)t seems to me the real systemic risk is that [Madoff] ends up being the next Refco and all their assets are frozen...."
+
+# JPMC's Head Of Risk Denies A Request To Increase The Bank's Risk Exposure to Madoff Securities By More Than \$1 Billion And Caps JPMC's Exposure At \$250 Million
+
+- 37. There was significant investor demand for the JPMC notes tied to the performance of the Madoff feeder funds. By June 2007, JPMC's position in Madoff feeder funds had created approximately \$105 million in risk exposure to Madoff Securities.
+- 38. In approximately June 2007, traders on the Equity Exotics Desk decided to ask for <sup>a</sup> combined risk limit exception for JPMC's exposure to Madoff Securities through the various feeder funds in order to meet increasing demand for the structured products. Ultimately, senior investment bankers — including the Head of Equities for the Europe, Middle East and Africa region ("EMEA") — decided to seek approval to underwrite approximately \$1 billion in Madoff-linked derivatives. Given the particular nature of the derivatives (some of which included features such as capital protection and offered the purchasers a degree of leverage), the \$1 billion issuance would have resulted in atotal of more than \$1.32 billion of the Bank's proprietary capital to be invested directly into Madoff feeder funds as <sup>a</sup>hedge, resulting in total exposure for JPMC of approximately \$1.14 billion if the value of the feeder funds fell to zero. It was estimated at the time that the proposed \$1 billion issuance, if approved, would bring the Equity Exotics Desk approximately \$55-70 million in revenue.
+- 39. Because of the size of the proposed risk exception, the Investment Bank's Chief Risk Officer (the "CRO") required the proposal to be presented to the Investment Bank's Hedge Fund Underwriting Committee (the "Committee"). The Committee, chaired by the CRO, was comprised of executives from various of JPMC's lines of business who were affected by transactions involving hedge funds. The decision whether to permit the requested risk exception rested ultimately with the CRO.
+
+1. 40. The Committee met to consider the Investment Bank's \$1.14 billion Madoff Securities proposal on June 15, 2007, at 11:00 AM, at JPMC's midtown-Manhattan offices. Investment Bank employees from the London Equity Exotics Desk participated by phone, and senior Equities executives – including the Investment Bank's Global Head of Equities – participated in person, as did other JPMC Executives from JPMC's Investment Bank. Executives from the B/D Group also participated by phone to address any questions relating to JPMC's banking or credit relationships with Madoff Securities.
+2. 41. In advance of the meeting, credit executives circulated written materials analyzing the proposed Madoff transaction. Among other things, those written materials described Madoff Securities as being a fund "in the order of \$15-20bn" – making it one of the largest hedge funds then in existence.
+3. 42. With respect to risk analysis, the written materials stated that there was little market risk associated with Madoff's investment strategy, and concluded that "the main risk this trade poses is systemic fraud risk at the BLM [*i.e.*, Bernard L. Madoff] level." Elsewhere, the materials reiterated that "[c]learly, our largest risk is that of wholesale fraud at BLM that would strip the firm of any real assets (balance sheet or customer)." The written materials reported that the prospect of a systemic fraud was "extremely unlikely." The written materials also reported that systemic fraud risk was further mitigated because even "under a fraud/insolvency event at BLM level JPM would be a senior creditor (together with other account holders of customer assets also protected by SIPC [the Securities Investor Protection Corporation] and should have priority in recovery above other creditors of BLM. It would therefore require a fraud/insolvency event of extreme proportions to erode the implied subordination in the JPM transactions (e.g. estimated \$15bn of assets run by BLM. . . )."
+4. 43. The presentation also made clear that although JPMC was able to conduct due diligence on some of the Madoff feeder funds, Madoff was unwilling to allow JPMC to conduct direct due diligence on Madoff Securities. The presentation material did report that JPMC personnel had spoken to Madoff by telephone on March 30, 2007. During this call, Madoff provided what JPMC employees considered to be forthcoming answers to questions posed about Madoff's purported investment strategy, but indicated that he did not approve of the Madoff-linked derivative products and would not allow JPMC to conduct due diligence on his fund directly.
+5. 44. The June 15, 2007 Committee meeting ended without the CRO's approval for any further exposure by JPMC to Madoff Securities. While the reported consensus of the Committee was that "the fraud risk at Madoff is remote," the CRO concluded that no approval would be granted unless JPMC could do "direct due diligence on Madoff Securities." The CRO stated in an e-mail that "we don't do \$1 bio [billion] trust me deals."
+6. 45. Shortly after the Committee meeting ended, the CRO had lunch with another JPMC Executive (the "JPMC Executive"). During the lunch, the CRO sent an e-mail to, among others, the Investment Bank's Global Head of Equities, the Head of Equities for EMEA, and the head of the Equity Exotics Desk stating: "I am sitting at lunch with [the JPMC Executive] who just told me that there is a well-known cloud over the head of Madoff"
+
+and that his returns are speculated to be part of a ponzi scheme – he said if we google the guy we can see the articles for ourselves – Pls do that and let us know what you find.” In follow-up correspondence with the CRO, the JPMC Executive provided more specifics about the article and offered to find the article if the CRO had any difficulty locating it, explaining that he knew “nothing” on the subject other than what he read in what was “definitely an unflattering article.”
+
+1. 46. In response to the CRO’s e-mail about the Madoff Ponzi scheme rumors, the Global Head of Equities wrote that JPMC should “seriously look into it” as JPMC lent Madoff Securities money through the B/D Banking Group. The Global Head of Equities also commented that it was “hard to believe this would be going on over the years” because Madoff Securities was “regulated by SEC, NYSE, NASD etc.” To this the CRO responded that “Refco was regulated by the same crowd [that regulates Madoff Securities] and there was noise about them for years before it was discovered to be rotten to the core,” adding that “we owe it to ourselves to investigate further.” And in another e-mail several days later, the CRO wrote to one of the co-Chief Executive Officers of the Investment Bank that the JPMC Executive “told me Madoff has a very shady reputation in the market.”
+2. 47. Neither the CRO nor anyone else at JPMC located the article to which the JPMC Executive had referred, although a junior JPMC employee conducted an unsuccessful search. The article referenced by the JPMC Executive was a 2001 Barron’s feature entitled “Don’t Ask, Don’t Tell: Bernie Madoff is so secretive, he even asks his investors to keep mum.” The Barron’s article, among other things, raised some of the same issues identified by JPMC’s risk analysts. For example, it noted Madoff Securities had “produced compound average annual returns of 15% for more than a decade,” and that “some of the larger, billion-dollar Madoff-run funds have never had a down year.” The article then reported that “some on the Street have begun speculating that Madoff’s market-making operation subsidizes and smooths his hedge-fund returns” and described how such smoothing could be accomplished through an unlawful practice known as front-running.
+3. 48. On or about June 27, 2007, the head of the Investment Bank’s structured products group e-mailed the CRO a “quick reminder” that JPMC had “client trades requiring \$150 mm of delta to buy in funds investing in Madoff on Friday of this week” and that there would be “further significant flows at next month end.” The CRO then requested and received additional information from the B/D Group about Madoff Securities, including information from its credit reviews. On the same day, the CRO also spoke by telephone to Madoff, who answered questions asked by the CRO. At the same time, the CRO understood that Madoff would not authorize any further direct due diligence on Madoff Securities.
+4. 49. Later the same day, June 27, 2007, the CRO wrote “we will approve up to \$250 mio for these trades,” then clarified that he was approving \$250 million of total risk exposure, to include both JPMC’s existing approximately \$105 million in exposure as well as exposure generated through new transactions by the Investment Bank. Based on the decision to set risk exposure at \$250 million, the Equity Exotics Desk ended its
+
+discussions related to other potential Madoff derivative transactions then under negotiation in order to stay within the risk limits.
+
+## June 2007 — September 2008: The EauiW Exotics Desk Monitors JPMC's Exposure to Medoff Securities
+
+- 50. In approximately August 2007, an Equity Exotics employee ("Equity Exotics Banker 1") conducted an analysis in order to determine the relationship between returns reported by <sup>a</sup>Medoff feeder fund and the investments in S&P 500 stocks and Treasury bills that Medoff claimed comprised his investment strategy. Equity Exotics Banker 1 was unable to determine based on available information how the Medoff feeder fund could have produced these returns had Medoff followed this strategy, writing that the market performance during the period analyzed was "far away" from the returns that Madoff "allegedly made." After obtaining further information and conducting further analysis, Equity Exotics Banker 1 e-mailed a colleague that he did "take comfort from the fact" that two separate Madoff feeder funds were reporting close to the same returns for the period.
+- 51. Also in the Fall of 2007, JPMC hired a"Head of Due Diligence" for the Equity Exotics Desk. On his first day on the job, the head of the Equity Exotics Desk directed the Head of Due Diligence to review the Medoff feeder fund positions and offer any insight into how Medoff was able to generate his purported returns. The Head of Due Diligence was unable to explain the returns and learned that the Equity Exotics Desk was no longer interested in issuing products linked to the returns of Madoff Securities.
+- 52. On June 23, 2008, after reviewing e-mails about the failure of one of the feeder funds to provide information to JPMC, including about how the money sent to Medoff was invested, and the departure of various feeder fund employees, asenior Equity Exotics banker e-mailed the head of the Equity Exotics Desk: "How much do we have in Madoff at the moment? To be honest, the more I think about it, the more concerned I am."
+- 53. In or around September 2008, as described below, JPMC began to consider redeeming its positions in the Medoff feeder funds.
+
+## October 2008: JPMC Concludes In A Report To U.K. Regulators That Madoff's Returns Are Probably Too Good To Be True
+
+- 54. In mid-September 2008, following the collapse of Lehman Brothers and growing concerns about counter-party risk, JPMC's Head of Global Equities directed investment bank personnel to substantially reduce JPMC's exposure to hedge funds, which had increased following JPMC's March 2008 acquisition of Bear Stearns. This directive was reiterated by the Investment Bank Risk Committee on October 3, 2008. Acting at the direction of the Head of Global Equities, the Equity Exotics Desk began analyzing which hedge funds to reduce exposure to, including by directing the Desk's due diligence analyst (the "Equity Exotics Analyst') to scrutinize investments in various hedge funds, including the Medoff feeder funds. The Equity Exotics Analyst conducted this due diligence by, among other things, analyzing the reported strategy and returns of Medoff
+
+Securities, speaking to personnel at Madoff feeder funds and financial institutions administering Madoff feeder funds, and unsuccessfully seeking from the feeder funds and administrators documentary proof of the assets of Madoff Securities.
+
+1. 55. On October 16, 2008, the Equity Exotics Analyst wrote a lengthy e-mail to the head of the Equity Exotics Desk and others summarizing his conclusions (the "October 16 Memo"). The October 16 Memo described the inability of JPMC or the feeder funds to validate Madoff's trading activity or custody of assets. The October 16 Memo noted that the feeder funds were audited by major accounting firms, which had issued unqualified opinions for 2007, but questioned Madoff's "odd choice" of a small, unknown accounting firm. The October 16, 2008 Memo reported that personnel from one of the feeder funds "said they were reassured by the claim that FINRA and the SEC performed occasional audits of Madoff," but that they "appear not to have seen any evidence of the reviews or findings." The October 16 Memo also questioned the reliability of information provided by the feeder funds and the willingness of the feeder funds to obtain verifying information from Madoff. For example, the memo reported that personnel at one feeder fund "seem[ed] very defensive and almost scared of Madoff. They seem unwilling to ask him any difficult questions and seem to be considering his 'interests' before those of the investors. It's almost a cult he seems to have fostered." The Equity Exotics Analyst further wrote that there was both a "lack of transparency" into Madoff Securities and "a resistance on the part of Madoff to provide meaningful disclosure."
+2. 56. The October 16 Memo ended with the observation that: "[t]here are various elements in the story that could make us nervous," including the fund managers' "apparent fear of Madoff, where no one dares to ask any serious questions as long as the performance is good." The October 16 Memo concluded: "I could go on but we seem to be relying on Madoff's integrity (or the [feeder funds'] belief in Madoff's integrity) and the quality of the due diligence work (initial and ongoing) done by the custodians . . . to ensure that the assets actually exist and are properly custodied. If some[thing] were to happen with the funds, our recourse would be to the custodians and whether they had been negligent or grossly negligent."
+3. 57. The Head of Due Diligence responded by complimenting the Equity Exotics Analyst on the October 16 Memo, making reference to other long-running fraud schemes, and suggesting in a joking manner that they should visit the Madoff Securities accountant's office in New City, New York to make sure it was not a "car wash."
+4. 58. The October 16 Memo was forwarded to JPMC's in-house and external counsel, as well as to JPMC's London-based Head of AML for the EMEA region, who also served as JPMC's designated BSA Officer for the region (the "EMEA BSA Officer"). Following review of the October 16 Memo and consultation with legal counsel, on or about October 29, 2008, the EMEA BSA Officer filed with the U.K. Serious Organised Crime Agency ("SOCA") a report, also called a suspicious activity report or SAR, pursuant to the terms of the United Kingdom's Proceeds of Fraud Act (the "U.K. Report"). The U.K. Report was filed by the EMEA BSA Officer on behalf of JPMorgan Chase Bank, N.A. – the OCC-regulated entity – and identified Madoff Securities as its "main subject – suspect." Under "reason for suspicion," the EMEA BSA Officer wrote, in pertinent part:
+
+JPMCB's [*i.e.*, JPMorgan Chase Bank, N.A.'s] concerns around Madoff Securities are based (1) on the investment performance achieved by its funds which is so consistently and significantly ahead of its peers year-on-year, even in the prevailing market conditions, as to appear too good to be true – meaning that it probably is; and (2) the lack of transparency around Madoff Securities trading techniques, the implementation of its investment strategy, and the identity of its OTC [over the counter] options counterparties; and (3) its unwillingness to provide helpful information. As a result, JPMCB has sent out redemption notices in respect of one fund, and is preparing similar notices for two more funds.
+
+1. 59. The U.K. Report continued that "JPMCB is also concerned about the conflict of interests which the three combined roles of BLM could represent" – *i.e.*, acting "as sub-advisor, sub-custodian and broker/dealer to the funds in question" – a factor also cited in the October 16 Memo regarding JPMC's inability to verify that the assets of Madoff Securities "actually exist." The U.K. Report further noted that other investment advisors had attempted to replicate Madoff's stated strategy "but nowhere near as successfully as BLM," and that the feeder fund managers "appear to know very little about how BLM strategy and systems work, and seem unconcerned in view of its consistent profitability." Under the heading "[o]f further concern," the U.K. Report also described the "small and unknown" auditors used by Madoff Securities.
+2. 60. The U.K. Report then quantified JPMC's Madoff-related hedge fund redemptions as being undertaken "as a result" of these suspicions: €150 million (out of a total of €200 million) from one fund, and \$150 million (out of a total of \$150 million) from another.
+3. 61. In addition to reporting JPMC's suspicion that Madoff Securities was claiming returns "too good to be true," the U.K. Report also identified a distributor of the Madoff-linked derivatives as a "secondary subject" of the report. The basis for JPMC's suspicions about the distributor was a call between a JPMC Investment Bank salesperson and an employee of the distributor in which JPMC informed the distributor that JPMC intended to invoke a provision of the note agreement enabling JPMC to delink the notes from the performance of a Madoff feeder fund. During the call, the distributor's employee expressed displeasure about JPMC's proposed action and referenced having "Colombian friends who cause havoc . . . when they get angry . . ."
+4. 62. On November 19, 2008, the EMEA BSA Officer filed a second report with SOCA in the United Kingdom, on behalf of JPMorgan Chase Bank, N.A. This report alerted British regulators to a proposal by JPMC to buy back certain of the Madoff-linked notes from investors linked to the distributor who had referenced "Colombian friends" and stated that "[c]learly we do not wish to make the legal offer if there is any risk that we could not meet our obligations if SOCA refused consent at a later date, on the basis that JPM could be considered party to laundering the proceeds of crime."
+
+63. Prior to filing either of the U.K. reports, a U.K. markets compliance officer (the "U.K. Markets Compliance Officer") and a JPMC lawyer based in the United Kingdom spoke to the Global Head of Equities about the Madoff redemptions and need to potentially file a report. The Global Head of Equities stated that Madoff was not an important client relationship to him. The Global Head of Equities also indicated that he supported taking any necessary steps with regard to "disclosure to US/UK regulators," and that he assumed JPMC's general counsel would be involved in the "ultimate decision." No disclosure was made to United States regulators and no report was made to JPMC's general counsel.
+
+JPMC's Redemptions From Madoff Feeder Funds
+
+64. On October 16, 2008 – the day of the October 16 Memo – an Equity Exotics employee requested by e-mail a "list of all external trades and the exact counterparty trade" for each of the Madoff-related feeder funds, noting that "[t]he list needs to be exhaustive as we may be terminating all of these trades and we cannot afford missing any." The Equity Exotics Desk, which had already placed redemption orders for approximately \$78 million from the Madoff feeder funds between October 1 and October 15, thereafter sought to redeem almost all of its remaining money in the Madoff feeder funds.
+
+65. In addition to redeeming its positions in the Madoff feeder funds, JPMC sought, with the assistance of legal counsel, to cancel or otherwise unwind certain of the structured products issued related to the performance of the Madoff feeder funds. In an attempt to unwind these transactions, JPMC told the distributors of the Madoff notes that it was invoking a provision of the derivatives contract that enabled it to de-link the notes from the performance of the Madoff feeder funds if JPMC could not obtain satisfactory information about its investment. For example, in a letter dated October 27, 2008, JPMC warned that it would declare a "Lock-In Event" under the terms of the contract unless the recipient – a distributor that the Equity Exotics Analyst had spoken to as part of his due diligence underlying the October 16 Memo – could provide the identity of all of Madoff Securities' options counterparties by 5:00 PM the following day.
+
+66. In the Fall of 2008, the amount of JPMC's position in Madoff feeder funds fell from approximately \$369 million at the beginning of October 2008 (which was down slightly from its high-water mark of \$379 million, in July 2008) to approximately \$81 million at the time of Madoff's arrest, on December 11, 2008 – a reduction of approximately \$288 million, or approximately 80% of JPMC's proprietary capital invested as a hedge in Madoff feeder funds. During the same period, JPMC spent approximately \$19 million buying back Madoff-linked notes and approximately \$55 million to unwind a swap transaction with a Madoff feeder fund that eliminated JPMC's contractual obligation with respect to those structured products. When Madoff was arrested, JPMC booked a loss of approximately \$40 million, substantially less than the approximately \$250 million it would have lost but for these transactions.
+
+67. At the same time, the Equity Exotics Desk also held through the time of Madoff's arrest a gap note providing JPMC with \$5 million in protection if the value of a Madoff feeder fund collapsed completely. In a November 28, 2008 e-mail, an Equity Exotics banker
+
+declined a third party's request to buy this protective gap note from JPMC, and described the gap note as being "as of today . . . very valuable" to JPMC.
+
+1. 68. Although JPMC sharply reduced its hedge position in Madoff feeder funds, it was exposed to substantial risk in the event that Madoff Securities continued to perform successfully because it had not been able to unwind or otherwise cancel an equivalent value of JPMC-issued notes linked to the performance of the Madoff feeder funds.
+2. 69. No one at the Investment Bank involved in JPMC's redemptions from the Madoff feeder funds informed anyone in the B/D Group of their concerns about the validity of Madoff's returns or even the fact of the redemptions. The key Investment Bank personnel involved in the Madoff feeder fund redemptions knew that the B/D Group had a banking relationship with Madoff Securities.
+
+JPMC's Failure to File a SAR in the United States
+
+1. 70. Although JPMC stated in the U.K. Report that a New York-based, SEC-regulated broker-dealer's reported returns were "probably too good to be true," JPMC failed to file a SAR in the United States.
+2. 71. The U.K.-based EMEA BSA Officer who filed the U.K. Report did not ask anyone in the United States AML compliance function to investigate the suspicions about Madoff Securities described in the U.K. Report. The EMEA BSA Officer placed a phone call to the JPMC BSA Officer (as defined in paragraph 6, above) but, upon failing to reach him, did not follow up with any other individual in the United States AML compliance function. The EMEA BSA Officer also contacted the Head of Global Compliance for JPMC about the threat to the JPMC employee referenced in paragraph 62 stemming from planned Madoff feeder fund redemptions and steps taken to address it, but did not raise any issue about the potential need to file a SAR in the United States. JPMC did not at the time have any formal protocol for the sharing of information about suspicious activity between geographic regions.
+3. 72. So that he would be prepared to answer questions in the event that the Global Head of Equities were to learn about the U.K. Report, the U.K. Markets Compliance Officer alerted a high-ranking compliance officer for JPMC's Investment Bank in the United States (the "Senior IB Compliance Officer") about the trading desk's suspicions concerning Madoff Securities, and, ultimately, the Senior IB Compliance Officer learned that a report in the U.K. had been filed (although he did not receive a copy). The U.K. Markets Compliance Officer did not ask the Senior IB Compliance Officer to undertake any AML review, and no such review was undertaken by United States AML personnel.
+4. 73. The U.K. Markets Compliance Officer also provided the Senior IB Compliance Officer with a copy of the October 16 Memo, as well as copies of the written materials that accompanied the original Madoff derivative proposal from June 2007. Both the October 16 Memo and the June 2007 written material identified, in numerous places, the decades-long banking relationship between Madoff Securities and JPMC, and the relationship in particular between Madoff Securities and JPMC's B/D Group. For example, the June
+
+2007 written materials specifically noted that "BLM is a relationship of JPMorgan's broker-dealer team in New York," *i.e.*, the B/D Group.
+
+1. 74. The Senior IB Compliance Officer did not alert U.S. AML Compliance personnel about the concerns expressed in the October 16 Memo. Nor did the Senior IB Compliance Officer take any steps to examine JPMC's banking relationship with Madoff or the activity within the Madoff Securities accounts at JPMC. The Senior IB Compliance Officer did informally discuss the information he had received about Madoff Securities with several colleagues during an impromptu conversation in a hallway. After that conversation, one of the participants in that conversation – on his own initiative – conducted internet-based research and located two articles that contained negative information about Madoff Securities: the 2001 Barron's article, discussed above, that the JPMC Executive had referred to in June 2007, and an article in a hedge fund industry publication called MAR/Hedge from 2001 entitled "Madoff Tops Charts; Skeptics Ask How."
+2. 75. The MAR/Hedge article identified Madoff Securities as having "\$6-\$7 billion in assets under management," which "would put it in the number one or two spot" in the list of the world's biggest hedge funds. The article noted Madoff's "positive returns for the last 11-plus years," with "little volatility," and reported that other fund managers had attempted to replicate Madoff's strategy with less success, and far more volatility. The MAR/Hedge article echoed the report in the Barron's article that Madoff could be "subsidizing" client returns from his market-making business, by front-running order flow.
+3. 76. The Senior IB Compliance Officer forwarded one of the two articles to markets compliance personnel in the U.K., and that article was ultimately forwarded to senior lawyers at JPMC in London. The Senior IB Compliance Officer has stated in connection with this investigation that, when he reviewed these articles in October 2008, he had viewed as significant that the concerns about the consistency of Madoff's returns and lack of transparency had been discussed in articles since 2001, because it suggested to him that regulators likely would have already examined the concerns about Madoff Securities.
+4. 77. On or about November 10, 2008, an AML compliance officer based in London who had assisted in drafting the U.K. Report wrote an e-mail that contained information about JPMC's redemptions from the Madoff feeder funds, and asked, "What other relationships, if any, does JPM have with either [a particular distributor] or Madoff Investment Securities?" A markets compliance officer responded, copying the U.S.-based Senior IB Compliance Officer and noting that JPMC had "lodged a report with the relevant U.K. authority" and that the Global Head of Compliance was "aware" of the report. The email also stated that, while U.K. personnel would examine JPMC's relationship with Madoff in that jurisdiction, "given Madoff is a U.S. broker dealer we may undertake significant business in the U.S. I've copied [the Senior IB Compliance Officer] to keep him apprised." No JPMC personnel took any action following this e-mail to investigate JPMC's banking relationship with Madoff Securities.
+
+- 78. At no time between October 16, 2008 and Madoff sarrest did JPMC file aSAR in the United States based on the suspicions articulated in the U.K. Report. Nor did anyone at JPMC during this time (a) examine the 703 Account; (b) inform the Madoff Securities relationship manager; (c) update the Madoff Securities KYC file; or (d) refer suspicions to any U.S.-based AML personnel.
+
+## Billions Of Dollars Were Transferred From The 703 Account After JPMC Redeemed Its Madoff Feeder Fund Investments And Filed The U.K. Report
+
+- 79. JPMC continued providing banking services to Madoff Securities through the B/D Group until Madoffs arrest. In particular, after filing the U.K. Report, JPMC continued to process banking transactions for Madoff Securities in the account used for the Ponzi scheme, i.e., the 703 Account, which was then being rapidly depleted through withdrawals as the scheme neared collapse.
+- 80. Whereas the balance in the 703 Account reached approximately \$5.6 billion in August 2008, by October 16, 2008 — the date of the October 16 Memo — the account balance had fallen to \$3.7 billion. Thirteen days later, when the U.K. Report was filed, the balance had fallen another \$700 million, to approximately \$3 billion. And in the five business days after the U.K. Report was filed, approximately \$2.450 billion more was withdrawn from the 703 Account, leaving abalance of approximately \$550 million, some ninety percent less than it had been in August of the same year.
+- 81. Most of the funds withdrawn during this period went to the same two feeder fund groups in which JPMC had invested — and then redeemed — JPMC's own funds. Between October 1 and October 28, 2008, JPMC placed redemption orders for approximately \$276 million from two particular feeder funds. On November 4, 2008, approximately \$1.3 billion was paid from the 703 Account to those two feeder fund groups in four transactions. Later in November 2008, JPMC placed redemptions orders for an additional approximately \$23.1 million from one of the funds; Madoff was arrested before those funds were ever received, however.
+- 82. On December 11, 2008, agents of the Federal Bureau of Investigation arrested Madoff. At the time of his arrest, there was approximately \$234 million remaining in the <sup>703</sup> Account. Between October 16, 2008 and Madoff s arrest, approximately \$3.5 billion of the \$3.7 billion in the Madoff Securities accounts at JPMC had been withdrawn to pay customer redemptions.
+- 83. On the day of Madoffs arrest, the Head of Due Diligence c-mailed the Equity Exotics Analyst who had drafted the October 16 Memo: "Can't say I'm surprised, can you?" The Equity Exotics Analyst replied: "No." On the same day, the EMEA BSA Officer who caused the U.K. Report to be filed stating that Madoff's returns appeared "too good to be true" e- mailed JPMC's BSA Officer and head of JPMC's AML department that Madoff Securities, "was the hedge fund that we reported 6 weeks ago and which I never had <sup>a</sup> one to one with you on. It came to pass." Additionally, on the same day, the JPMC head of structured products e-mailed the Global Head of Equities about the amount JPMC had been able to redeem from Madoff feeder funds before Madoffs arrest, commenting "we
+
+got this one right at least — I said it looked too good to be true on that call with you in Sep[tember]." Finally, on the same day, the CRO e-mailed senior JPMC executives and wrote that with respect to Madoff, "we actually look like we have some clue of what we're doing," reporting that the investment bank had "got out of all but \$36 mio [million]" of "\$200 mio (down from the \$1 bio that [an investment bank executive] pushed hard for last year)." The CRO wrote further that the Chief Investment Officer of JPMC's private bank had "told us a lot of our Private Bank customers have invested with Madoff but luckily we didn't place any there."
+
+- 84. On March 12, 2009, Madoff pleaded guilty to securities fraud, wire fraud, money laundering, and related offenses, and was subsequently sentenced to 150 years' imprisonment. These offenses, and others, were committed through transactions using Madoff's 703 Account at JPMC.
+- 85. After Madoff's arrest, JPMC AML personnel examined the 703 Account transactions and filed a series of SARs relating to suspicious transactions in that account. JPMC did not file any SAR in the United States relating to Madoff prior to his arrest
+
+# Exhibit D
+
+PREET BHARARA United States Attorney for the Southern District of New York By: MATTHEW L. ARLO DF.VLIN-Assistant United States Attorneys One Saint Andrew's Plaza New York, New York 10007 Telephone: (212) 637-1945 Facsimile: (212) 637-2452 E-mail:
+
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+)
+
+UNITED STATES OF AMERICA, )
+
+)
+
+Plaintiff, )
+
+)
+
+- against - )
+
+)
+
+\$1,700,000,000 IN UNITED STATES ) CURRENCY, )
+
+)
+
+Defendant-in-rem. )
+
+) ) )
+
+# VERIFIED COMPLAINT
+
+No. 14 Civ.
+
+ECF Case
+
+Plaintiff the United States of America (the "Government"), by its attorney Preet Bharara, United States Attorney for the Southern District of New York, for its verified complaint (the "Complaint") alleges, upon information and belief, as follows:
+
+# INTRODUCTION
+
+1. This action is brought by the Government pursuant to 18 U.S.C. § 981 seeking forfeiture of certain property traceable to the Ponzi scheme orchestrated by Bernard L. Madoff ("Madoff'), which was conducted through a demand deposit account, and other linked
+
+accounts, maintained at JPMorgan Chase Bank, N.A., its affiliates, and their predecessors (collectively and separately, "JPMC.").
+
+2. By this Complaint, the Government seeks forfeiture of all right, title and interest in \$1,700,000,000 in United States currency (the "Defendant Funds"), which JPMC has agreed to forfeit to the United States pursuant to a Deferred Prosecution Agreement.
+
+3. Upon entry of a final order forfeiting the Defendant Funds to the United States, the Government intends to distribute the funds to victims of the fraud, consistent with the applicable Department of Justice regulations, through the ongoing remission process. See 21 U.S.C. § 853(i)(1) and 28 C.F.R. Part 9.
+
+# JURISDICTION AND VENUE
+
+4. This Court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1345 and 1355.
+
+5. Venue is proper pursuant to 28 U.S.C. § 1355(bX1)(A) because acts and omissions giving rise to the forfeiture took place in the Southern District of New York.
+
+## FACTUAL. ALLEGATIONS
+
+6. The Government's claims for forfeiture arise out of the investigation of Bernard I.. Madoff Investment Securities I.LC, and its predecessor, Bernard L. Madoff Investment Securities (collectively and separately, "Madoff Securities").
+
+7. At all relevant times to this Complaint, Madoff Securities had its principal place of business in New York, New York. Madoff Securities operated three principal lines of business: market making, proprietary trading, and investment advisory. Madoff Securities was registered with the United States Securities and Exchange Commission ("SEC") as a broker-dealer since in or about 1960 and as an investment adviser since in or about August 2006. Madoff was the founder of Madoff Securities and its sole owner.
+
+8. For more than three decades, the Madoff Securities investment advisory business was a massive, multi-billion dollar Ponzi scheme. From at least as early as the 1970s through Madoffs arrest on December II, 2008, Madoff and his co-conspirators fraudulently promised investors in Madoff Securities that their money would be invested in stocks, options, and other securities of well-known corporations. Contrary to these representations, investor money was in fact virtually never invested as promised. Instead, the Madoff Securities investment advisory business operated as a massive Ponzi scheme in which some investors were paid with money "invested" by different investors, and other proceeds were used to personally benefit Madoff and the people around him. At the time of its collapse in December 2008, Madoff Securities maintained more than 4,000 investment advisory client accounts, which purported to have a combined balance of approximately \$65 billion. In fact, Madoff Securities had only approximately \$300 million in assets at the time.
+
+9. From in or about October 1986 through Madoff's arrest on December 11, 2008, the Madoff Ponzi scheme was conducted almost exclusively through a demand deposit account and other linked cash and brokerage accounts held at JPMC. During that time period, virtually all client investments were deposited into the primary Madoff Securities account at JPMC, and virtually all client "redemptions" were paid from a linked disbursement account, also held by Madoff Securities at JPMC.
+
+10. On March 12, 2009, in connection with the Ponzi scheme operated through Madoff Securities, Madoff pleaded guilty to Information 09 Cr. 213 (DC), which charged him with securities fraud, investment advisor fraud, mail fraud, wire fraud, two counts of international money laundering, money laundering, false statements, perjury, false filings with the SEC, and theft from an employee benefit plan. Among other things, Madoff admitted that
+
+despite his promise to clients and prospective clients that he would invest their money in shares of common M, options, and other securities of well-known corporations, he in fact almost never invested those clients' funds in the securities as he had promised. Medoff further admitted that he attempted to conceal his fraud by, among other things, issuing false account statements and otherwise deceiving his investment advisory clients, lying to regulators, and wiring money between Medoff Securities and its London-based affiliate to create the impression that Madoff Securities was actually trading securities.
+
+11. On June 29, 2009, the Honorable Denny Chin sentenced Medoff to 150 years' imprisonment and criminal forfeiture.
+
+# THE DEFENDANT IN REM
+
+12. On or about January 6, 2014, JPMC entered into a Deferred Prosecution Agreement with the United States. Pursuant to that agreement, JPMC agreed to forfeit to the United States \$1,700,000,000, i.e., the Defendant Funds. The Defendant Funds represent proceeds of Madoff's fraud, and constitute some of the billions of dollars that flowed through the Medoff Securities accounts at JPMC during the course of the Ponzi scheme, including from the point in October 2008 that JPMC reported to regulators in the United Kingdom that JPMC had suspicions about the legitimacy of Medoff Securities.
+
+13. Specifically, on or about October 29, 2008, JPMC filed a report with the United Kingdom Serious Organised Crime Agency ("SOCA") pursuant to the U.K. Proceeds of Crime Act. In that report, which identified Madoff Securities as its "Main Subject — Suspect," JPMC reported that, among other things, "the investment performance achieved by [the Madoff Securities] funds . . . is so consistently and significantly ahead of its peers year-on-year, even in the prevailing market conditions, as to appear too good to be true — meaning that it probably is." JPMC reported that, "[ajs a result," it had submitted redemption requests for more than \$300 million of its own funds, which were invested in Madoff Securities "feeder" funds.
+
+14. Between the date of JPMC's report to SOCA and the date of Madoff s arrest, the balance of the Madoff Securities accounts at JPMC fell from approximately \$3 billion, to approximately \$234 million as a result of withdrawals paid to Madoffs investors as fictitious redemptions. The \$1.7 billion that JPMC has agreed to forfeit to the United States pursuant to the Deferred Prosecution Agreement represents a portion of the funds leaving the Madoff Securities accounts at JPMC from October 29, 2008 (i.e., the date of JPMC's report to SOCA) until Madoff s arrest on December 11, 2008, and is in an amount substantially greater than the value of all the funds redeemed by JPMC from the Madoff-linked feeder funds.
+
+15. The Deferred Prosecution Agreement and accompanying Statement of Facts are attached as Exhibit 1, and arc incorporated fully into this Complaint as if they had been set forth herein.
+
+# CLAIM FOR FORFEITURE (18 U.S.C. § 981(a)(1)(C))
+
+16. The Government incorporates by reference paragraphs 1 through 15 above as if fully set forth herein.
+
+17. Pursuant to 18 U.S.C. § 981(a)(l)(C), "EaThy property, real or personal, which constitutes or is derived from proceeds traceable to . . . any offense constituting `specified unlawful activity' . . . , or a conspiracy to commit such offense," is subject to forfeiture to the Government.
+
+IS. "Specified unlawful activity" is defined in 18 U.S.C. § 1956(O(7) to include, among other things, any offense listed under 18 U.S.C. § 1961(1). Section 1961(1) lists,
+
+among other things, violations of 18 U.S.C. §§ 1341 (mail fraud), 1343 (wire fraud), and "fraud in the sale of securities."
+
+19. Pursuant to 18 U.S.C. § 981(a)(2)(A), for purposes of the civil forfeiture statutes, "proceeds" refers to "property of any kind obtained directly or indirectly, as <sup>a</sup> result of the commission of the offense giving rise to forfeiture, and any property traceable thereto, and is not limited to the net gain or profit realized from the offense."
+
+20. As a result, the Defendant Funds are subject to forfeiture to the United States of America, pursuant to 18 U.S.C. § 981(a)(I)(C), because the Defendant Funds constitute property derived from Madoff's mail fraud, wire fraud, and securities fraud.
+
+[REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK]
+
+# REQUEST FOR RELIEF
+
+WHEREFORE plaintiff, the United States of America, requests that judgment be entered in its favor and against the Defendant Funds, and that process issue to enforce the forfeiture of the Defendant Funds, and that all persons having an interest in the Defendant Funds be cited to appear and show cause why the forfeiture should not be decreed, and that this Court decree forfeiture of the Defendant Funds to the United States of America for disposition according to law, and that this Court grant the Government such further relief as this Court may deem just and proper, together with the costs and disbursements in this action.
+
+Dated: New York, New York January 6, 2014
+
+> PREET BHARARA United States Attorney Attorney for the United States of America
+
+L. CHWARTZ ARLO DEVLIN-Assistant United States Attorneys One Saint Andrew's Plaza New York, New York 10007 Telephone: (212) 637-1945 Facsimile: (212) 637-2452 E-mail:
+
+## VERIFICATION
+
+STATE OF NEW YORK COUNTY OF NEW YORK SOUTHERN DISTRICT OF NEW YORK )
+
+PAUL M. TAKI,A, being duly sworn, deposes and says that he is aSpecial Agent with the Federal Bureau of Investigation, and as such has responsibility for the within action; that he has read the foregoing Verified Complaint and knows the contents thereof, and that the same is true to the best of his knowledge, information, and belief.
+
+The sources of deponent's information and the ground of his belief are official records and files of the United States, information obtained directly by the deponent, and information obtained by other law enforcement officials and representatives during an investigation of alleged violations of Titles 15, 18, and 31, United States Code.
+
+Sworn to before me this 6th day of January, 2014:
+
+NOTARY PUBLIC
+
+Climq YN i Vt L Nola's,. Public • State of New York NO 02E V6083677 Oualiffea in Kings Cou ty My Commission Expires
+
+PAUL M. TAKLA Special Agent Federal Bureau of Investigation
\ No newline at end of file
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+## EXHIBIT 2
+
+## Exhibit 3.1
+
+## RESTATED CERTIFICATE OF INCORPORATION of JPMORGAN CHASE & CO.
+
+Under Section 245
+
+of the
+
+General Corporation Law of the State of Delaware
+
+JPMorgan Chase & Co. (the "Corporation"), does hereby certify under the seal of the Corporation as follows:
+
+First: The name of the Corporation is JPMorgan Chase & Co.; the Corporation was originally incorporated as Chemical New York Corporation.
+
+Second: The Certificate of Incorporation of the Corporation was filed with the Secretary of State of the State of Delaware in Dover, Delaware, on the 28th day of October, 1968.
+
+Third: This Restated Certificate of Incorporation was duly adopted in accordance with Section 245 of the General Corporation Law of Delaware and only restates and integrates and does not further amend the provisions of the Corporation's Restated Certificate of Incorporation as heretofore restated, amended and supplemented. There is no discrepancy between those provisions and the provisions of this Restated Certificate of Incorporation.
+
+Fourth: The text of the Restated Certificate of Incorporation of the Corporation, as amended, is hereby restated to read in full, as follows:
+
+FIRST The name of the Corporation is JPMorgan Chase & Co.
+
+SECOND The address of its registered office in the State of Delaware is Corporation Trust Center, 1209 Orange Street, Wilmington, New Castle County, Delaware 19801. The name of its registered agent at such address is The Corporation Trust Company.
+
+THIRD The purpose of the Corporation is to engage in any lawful act or activity for which corporations may be organized under the General Corporation Law of Delaware. Without limiting in any manner the scope and generality of the foregoing, the Corporation shall have the following purposes and powers:
+
+- 1. To acquire by purchase, subscription, or otherwise, and to receive, hold, own, guarantee, sell, assign, exchange, transfer, mortgage, pledge, or otherwise dispose of or deal in and with any and all securities, as such term is hereinafter defined, issued or created by any corporation, firm, organization, association or other entity, public or private, whether formed under the laws of the United States of America or of any state, commonwealth, territory, dependency or possession thereof, or of any foreign country or of any political subdivision, territory, dependency, possession or municipality thereof, or issued or created by the United States of America or any state or commonwealth thereof or any foreign country, or by any agency, subdivision, territory, dependency, possession or municipality of any of the foregoing, and as owner thereof to possess and exercise all the rights, powers and privileges of ownership, including the right to execute consents and vote thereon;
+- 2. to make, establish and maintain investments in securities, and to supervise and manage such investments;
+- 3. to cause to be organized under the laws of the United States of America or of any state, commonwealth, territory, dependency or possession thereof, or of any foreign country or of any political subdivision, territory, dependency, possession or municipality thereof, one or
+
+more corporations, firms, organizations, associations or other entities and to cause the same to be dissolved, wound up, liquidated, merged or consolidated;
+
+1. 4. to acquire by purchase or exchange, or by transfer to or by merger or consolidation with the Corporation or any corporation, firm, organization, association or other entity owned or controlled, directly or indirectly, by the Corporation, or to otherwise acquire, the whole or any part of the business, good will, rights or other assets of any corporation, firm, organization, association or other entity, and to undertake or assume in connection therewith the whole or any part of the liabilities and obligations thereof, to effect any such acquisition in whole or in part by delivery of cash or other property, including securities issued by the Corporation, or by any other lawful means;
+2. 5. to make loans and give other forms of credit, with or without security, and to negotiate and make contracts and agreements in connection therewith;
+3. 6. to aid by loan, subsidy, guaranty or in any other lawful manner any corporation, firm, organization, association or other entity of which any securities are in any manner directly or indirectly held by the Corporation or in which the Corporation or any such corporation, firm, organization, association or entity may be or become otherwise interested; to guarantee the payment of dividends on any ██████ issued by any such corporation, firm, organization, association or entity; to guarantee or, with or without recourse against any such corporation, firm, organization, association or entity, to assume the payment of the principal of, or the interest on, any obligations issued or incurred by such corporation, firm, organization, association or entity; to do any and all other acts and things for the enhancement, protection or preservation of any securities which are in any manner, directly or indirectly, held, guaranteed or assumed by the Corporation, and to do any and all acts and things designed to accomplish any such purpose;
+4. 7. to borrow money for any business, object or purpose of the Corporation from time to time, without limit as to amount; to issue any kind of evidence of indebtedness, whether or not in connection with borrowing money, including evidences of indebtedness convertible into ██████ of the Corporation, to secure the payment of any evidence of indebtedness by the creation of any interest in any of the property or rights of the Corporation, whether at that time owned or thereafter acquired;
+5. 8. to render service, assistance, counsel and advice to, and to act as representative or agent in any capacity (whether managing, operating, financial, purchasing, selling, advertising or otherwise) of, any corporation, firm, organization, association or other entity; and
+6. 9. to engage in any commercial, financial, mercantile, industrial, manufacturing, marine, exploration, mining, agricultural, research, licensing, servicing, or agency business not prohibited by law, and any, some or all of the foregoing.
+
+The term "securities" as used in this Certificate of Incorporation shall mean any and all notes, stocks, treasury stocks, bonds, debentures, evidences of indebtedness, certificates of interest or participation in any profit-sharing agreement, collateral-trust certificates, preorganization certificates or subscriptions, transferable shares, investment contracts, voting trust certificates, certificates of deposit for a security, fractional undivided interests in oil, gas, or other mineral rights, or, in general, any interests or instruments commonly known as "securities", or any and all certificates of interest or participation in, temporary or interim certificates for, receipts for, guaranties of, or warrants or rights to subscribe to or purchase, any of the foregoing.
+
+The purposes and powers specified in the foregoing paragraphs shall, except where otherwise expressed, be in nowise limited or restricted by reference to, or inference from, the terms of any other paragraph in this Certificate of Incorporation, but the purposes and powers specified in each of the foregoing paragraphs of this Article THIRD shall be regarded as independent purposes and powers.
+
+The Corporation shall possess and may exercise all powers and privileges necessary or convenient to effect any or all of the foregoing purposes, or to further any or all of the
+
+foregoing powers, and the enumeration herein of any specific purposes or powers shall not be held to limit or restrict in any manner the exercise by the Corporation of the general powers and privileges now or hereafter conferred by the laws of the State of Delaware upon corporations formed under the General Corporation Law of Delaware.
+
+FOURTH The total number of shares of all classes of capital ██████ which the Corporation shall have authority to issue is NINE BILLION TWO HUNDRED MILLION, of which TWO HUNDRED MILLION shares shall be shares of preferred ██████ of the par value of \$1 per share (hereinafter called "Preferred ██████") and NINE BILLION shares shall be shares of common ██████ of the par value of \$1 per share (hereinafter called "Common ██████").
+
+Any amendment to this Certificate of Incorporation which shall increase or decrease the authorized capital ██████ of the Corporation may be adopted by the affirmative vote of the holders of capital ██████ representing not less than a majority of the voting power represented by the outstanding shares of capital ██████ of the Corporation entitled to vote.
+
+The designations and the powers, preferences and rights, and the qualifications, limitations or restrictions thereof, of the Preferred ██████ shall be as follows:
+
+(1) The Board of Directors is expressly authorized at any time, and from time to time, to provide for the issuance of shares of Preferred ██████ in one or more series, with such voting powers, full or limited but not to exceed one vote per share, or without voting powers and with such designations, preferences and relative, participating, optional or other special rights, and qualifications, limitations or restrictions thereof, as shall be stated and expressed in the resolution or resolutions providing for the issue thereof adopted by the Board of Directors, and as are not stated and expressed in this Certificate of Incorporation, or any amendment thereto, including (but without limiting the generality of the foregoing) the following:
+
+1. a. the designation of such series;
+2. b. the dividend rate of such series, the conditions and dates upon which such dividends shall be payable, the preference or relation which such dividends shall bear to the dividends payable on any other class or classes or on any other series of any class or classes of capital ██████, and whether such dividends shall be cumulative or non-cumulative;
+3. c. whether the shares of such series shall be subject to redemption by the Corporation, and, if made subject to such redemption, the times, prices and other terms and conditions of such redemption;
+4. d. the terms and amount of any sinking fund provided for the purchase or redemption of the shares of such series;
+5. e. whether or not the shares of such series shall be convertible into or exchangeable for shares of any other class or classes or of any other series of any class or classes of capital ██████ of the Corporation, and, if provision be made for conversion or exchange, the times, prices, rates, adjustments and other terms and conditions of such conversion or exchange;
+6. f. the extent, if any, to which the holders of the shares of such series shall be entitled to vote as a class or otherwise with respect to the election of the directors or otherwise; provided, however, that in no event shall any holder of any series of Preferred ██████ be entitled to more than one vote for each share of such Preferred ██████ held by him;
+7. g. the restrictions, if any, on the issue or reissue of any additional Preferred ██████;
+8. h. the rights of the holders of the shares of such series upon the dissolution of, or upon the distribution of assets of, the Corporation.
+
+(2) Except as otherwise required by law and except for such voting powers with respect to the election of directors or other matters as may be stated in the resolutions of the Board of Directors
+
+**FIFTH** The by-laws may be made, altered, amended or repealed by the Board of Directors. The books of the Corporation (subject to the provisions of the laws of the State of Delaware) may be kept outside of the State of Delaware at such places as from time to time may be designated by the Board of Directors.
+
+**SIXTH** (1) To the fullest extent that the General Corporation Law of the State of Delaware as it exists on the date hereof or as it may hereafter be amended permits the limitation or elimination of the liability of directors, no director of the Corporation shall be personally liable to the Corporation or its stockholders for monetary damages for breach of fiduciary duty as a director.
+
+(2) The Corporation shall have the power to indemnify any director, officer, employee or agent of the Corporation or any other person who is serving at the request of the Corporation in any such capacity with another corporation, partnership, joint venture, trust or other enterprise (including, without limitation, any employee benefit plan) to the fullest extent permitted by the General Corporation Law of the State of Delaware as it exists on the date hereof or as it may hereafter be amended, and any such indemnification may continue as to any person who has ceased to be a director, officer, employee or agent and may inure to the benefit of the heirs, executors and administrators of such a person.
+
+(3) By action of its Board of Directors, notwithstanding any interest of the directors in the action, the Corporation may purchase and maintain insurance, in such amounts as the Board of Directors deems appropriate, to protect any director, officer, employee or agent of the Corporation or any other person who is serving at the request of the Corporation in any such capacity with another corporation, partnership, joint venture, trust or other enterprise (including, without limitation, any employee benefit plan) against any liability asserted against him or incurred by him in any such capacity or arising out of his status as such (including, without limitation, expenses, judgments, fines and amounts paid in settlement) to the fullest extent permitted by the General Corporation Law of the State of Delaware as it exists on the date hereof or as it may hereafter be amended, and whether or not the Corporation would have the power or would be required to indemnify any such person under the terms of any agreement or by-law or the General Corporation Law of the State of Delaware. For purposes of this paragraph (3), "fines" shall include any excise taxes assessed on a person with respect to any employee benefit plan.
+
+**SEVENTH** (1) Any action required or permitted to be taken by the holders of Common [REDACTED] of the Corporation must be effected at a duly called annual or special meeting of the stockholders of the Corporation and may not be effected by any consent in writing.
+
+(2) Whenever the vote of holders of shares of any class or series other than Common [REDACTED] at a meeting thereof is required or permitted to be taken for or in connection with any corporate action by any provision of the General Corporation Law of the State of Delaware, the meeting and vote of such stockholders may be dispensed with if such action is taken with the written consent of such holders representing not less than a majority of the voting power of all the capital [REDACTED] of such class or series entitled to be voted upon such action if a meeting were held; provided that in no case shall the written consent be by such holders having less than the minimum percentage of the vote required by statute for such action, and provided that prompt notice is given in writing to all such stockholders entitled to vote thereon of the taking of corporate action without a meeting and by less than unanimous written consent.
+
+(3) Election of directors need not be by ballot unless the by-laws so provide.
+
+**EIGHTH** The Corporation reserves the right to amend, alter, change or repeal any provision contained in this Certificate of Incorporation, in the manner now or hereafter prescribed by statute, and all rights conferred upon stockholders herein are granted subject to this reservation.
+
+IN WITNESS WHEREOF, the Corporation has caused this certificate to be signed by its authorized officer and caused the corporate seal of the Corporation to be hereunto affixed this 3M day of April 2006.
+
+BLALAnfhoey\_Liioran
+
+Anthony J. Horan
+
+Corporate Secretary
+
+LCsraaatrSrall
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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+Case No. 1:23-CV-03903 (JSR)
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+## DERIVATIVE ACTION
+
+## DECLARATION OF AUDRA J. SOLOWAY IN SUPPORT OF DEFENDANTS' MOTION TO DISMISS THE AMENDED STOCKHOLDER DERIVATIVE COMPLAINT
+
+AUDRA J. SOLOWAY declares the following pursuant to 28 U.S.C. § 1746:
+
+I. I am a member of the law firm Paul, Weiss, Riflcind, Wharton & Garrison LLP, 1285 Avenue of the Americas, attorneys for defendants Stephen M, Todd Combs, James Crown, Timothy Flynn, Mellody Hobson, John Kessler, and Phebe Novakovic (together, with JPMorgan Chase & Co. and James Dimon, "Defendants"). I submit this declaration in support of Defendants' Motion to Dismiss the Amended Stockholder Derivative Complaint.
+
+2. Attached hereto as Exhibit 1 is a true and correct copy of the Deferred Prosecution Agreement and accompanying exhibits, entered into by JPMorgan Chase Bank, N.A. and the Office of the United States Attorney for the Southern District of New York on January 6, 2014.
+
+3. Attached hereto as Exhibit 2 is a true and correct copy of the Restated Certificate of Incorporation of JPMorgan Chase & Co., effective April 5, 2006 (incorporated by reference to Exhibit 3.1 to the Current Report on Form 8-K of JPMorgan Chase & Co. filed April 7, 2006).
+
+I declare under penalty of perjury that the foregoing is true and correct.
+
+Executed on: July 6, 2023. New York, New York
+
+/s/ Audra J. Soloway
+
+Audra J. Soloway
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+#### UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+Case No. 1:23-CV-03903 (JSR) DERIVATIVE ACTION
+
+### STIPULATION AND I PROPOSEDI PROTECTIVE ORDER
+
+The parties having agreed to the following terms of confidentiality, and the Court having found that good cause exists for issuance of an appropriately tailored confidentiality order governing the pre-trial phase of this action, it is therefore hereby
+
+ORDERED that any person subject to this Order -- including without limitation the parties to this action, their representatives, agents, experts and consultants, all third parties providing discovery in this action, and all other interested persons with actual or constructive notice of this Order -- shall adhere to the following terms, upon pain of contempt:
+
+- I. Any person subject to this Order who receives from any other person any "Discovery Material" (te., information of any kind provided in the course of discovery in this action) that is designated as "Confidential" pursuant to the terms of this Order shall not disclose such Confidential Discovery Material to anyone else except as expressly permitted hereunder.
+- 2. The person producing any given Discovery Material may designate as Confidential only such portion of such material as consists of:
+  - a. previously nondisclosed financial information (including without limitation profitability reports or estimates, percentage fees, design fees, royalty rates, minimum guarantee payments, sales reports and sale margins);
+
+- b. previously nondisclosed confidential reporting to law enforcement agencies;
+- c. previously nondisclosed material relating to ownership or control of any non-public company;
+- d. previously nondisclosed business plans, product development information, or marketing plans;
+- e. any information of a personal or intimate nature regarding any individual;
+- 1. any information maintained by JPMorgan Chase Bank, N.A. or its affiliates that is required to be kept confidential pursuant to the Bank Secrecy Act, 31 U.S.C. §§ 5311 to 5336, or its implementing regulations ("BSA") but for which the appropriate regulatory authority has authorized disclosure, including but not limited to the fact that no BSA information exists, ("BSA-Protected Information")' and any information that, pursuant to 31 U.S.C. 53I8(g)(2)(A)( I ), 31 C.F.R. § 1020.320, 12 C.F.R § 21.11, Section 3I4(a) or (b) of the PATRIOT ACT, 12 U.S.C. §§ 3414(aX3) and (c) or any other applicable regulations concerning potential suspicious activity ("SAR-Related Information"), is not permitted to be produced unless authorized by the appropriate regulatory authority ("SAR-Protected Information");
+- g. any information that is confidential supervisory information ("cm of the Board of Governors of the Federal Reserve System as set forth in 12 C.F.R. § 261.2(c), non-public information of the Office of the Comptroller of the
+
+BSA-Protected Information maintained by other financial institutions are not within the scope of this Order and remain subject to the standard confidentiality requirements of the BSA and its implementing regulations.
+
+Currency or the former Office of Thrift Supervision as set forth in 12 C.F.R. § 4.32(b), exempt information of the Federal Deposit Insurance Corporation as set forth in 12 C.F.R. §§ 309.2, 309.5, and 309.6, and confidential information of the Consumer Financial Protection Board as set forth in 12 C.F.R. § 1070.2, and any other records concerning supervision, regulation, and examination of banks, savings associations, their holding companies and affiliates, and records compiled in connection with the enforcement responsibilities of federal and state financial regulatory agencies that is not permitted to be disclosed to a third party absent consent of the applicable regulator or government agency unless authorized by the appropriate regulatory authority ("CSI-Protected Information"); or
+
+- h. any other category of information hereinafter given confidential status by the Court.
+
+3. With respect to the Confidential portion of any Discovery Material other than deposition transcripts and exhibits, the producing person or that person's counsel may designate such portion as "Confidential" by stamping or otherwise clearly marking as "Confidential" the protected portion in a manner that will not interfere with legibility or audibility, and by also producing for future public use another copy of said Discovery Material with the confidential information redacted. For the avoidance of doubt, nothing herein is intended to prevent a party from designating the entirety of a given document as "Confidential" if the party reasonably believes the entire document falls within one or more of the categories in paragraph 2, above. With respect to deposition transcripts and exhibits, a producing person or that person's counsel may indicate on the record that a question calls for Confidential information, in which case the transcript
+
+of the designated testimony shall be bound in a separate volume and marked "Confidential Information Governed by Protective Order" by the reporter.
+
+4. If at any time prior to the trial of this action, a producing person realizes that some portion[s] of Discovery Material that that person previously produced without limitation should be designated as Confidential, he may so designate by so apprising all parties in writing, and such designated portion[s] of the Discovery Material will thereafter be treated as Confidential under the terms of this Order. If a party has disclosed such designated portion[s] of Discovery Material to anyone other than the individuals set forth in paragraph 5 below, that party shall make reasonable efforts to promptly retrieve such Discovery Material, and inform any recipient of the terms of the Order.
+
+5. With the exception of the qualifications pertaining to BSA-Protected Information, SAR-Protected Information and/or CSI-Protected Information in paragraph 6, no person subject to this Order other than the producing person shall disclose any of the Discovery Material, designated by the producing person as Confidential excluding any material containing BSA-Protected Information, SAR-Protected Information and/or CSI-Protected Information to any other person whomsoever, except to:
+
+- a. the parties to this action;
+- b. counsel retained specifically for this action, including any paralegal, clerical and other assistant employed by such counsel and assigned to this matter;
+- c. as to any document, its author, its addressee, and any other person indicated on the face of the document as having received a copy;
+- d. any witness who counsel for a party in good faith believes may be called to testify at trial or deposition in this action, provided such person has first
+
+executed a Non-Disclosure Agreement in the form annexed as an Exhibit hereto;
+
+- e. any person retained by a party to serve as an expert witness or otherwise provide specialized advice or services to counsel in connection with this action (including but not limited to professional jury or trial consultants, mock jurors, and persons or entities providing litigation support services such as photocopying, videotaping, translating, preparing exhibits or demonstrations, and processing, hosting, organizing, storing, or retrieving data in any form or medium — and their employees and subcontractors), provided such person has first executed a Non-Disclosure Agreement in the form annexed as an Exhibit hereto;
+- f. any mediator or other dispute-resolution personnel, or any employee thereof, provided such person has first executed a Non-Disclosure Agreement in the form annexed as Exhibit hereto;
+- g. insurers, reinsurers, insurance adjusters, and/or third party administrators of insurance policies that do or may provide insurance coverage applicable to this action;
+- h. stenographers engaged to transcribe depositions conducted in this action and videographers engaged to record depositions conducted in this action; and
+- i. the Court and its support personnel.
+- 6. No person subject to this Order shall disclose any BSA-Protected Information, SAR-Protected Information, and/or CSI-Protected Information to any other person whomsoever,
+
+except to the following persons, consistent with any authorization received from the appropriate regulatory authority:
+
+- a. the parties and their counsel, including any paralegal, clerical and other assistant employed by such counsel and assigned to this matter;
+- b. any witness employed or formerly employed by JPMorgan Chase & Co. or JPMorgan Chase Bank, N.A., or any witness who serves or formerly served on the Board of Directors of JPMorgan Chase & Co. or JPMorgan Chase Bank, N.A., who counsel for the parties in good faith believes may be called to testify at trial or deposition in this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as an Exhibit hereto;
+- c. any person retained by the parties to serve as an expert witness or otherwise provide specialized advice to counsel in connection with this action, provided such person has first executed a Non-Disclosure Agreement in the form annexed as an Exhibit hereto;
+- d. stenographers engaged to transcribe depositions conducted in this action and videographers engaged to record depositions conducted in this action provided such person has first executed a Non-Disclosure Agreement in the form annexed as Exhibit hereto; and
+- e. the Court and its support personnel.
+
+7. Prior to any disclosure of any Confidential Discovery Material to any person referred to in subparagraphs 5(d), 5(e), or 5(f) above, such person shall be provided by counsel with a copy of this Protective Order and shall sign a Non-Disclosure Agreement in the form annexed as an Exhibit hereto stating that that person has read this Order and agrees to be bound by its terms. Said counsel shall retain each signed Non-Disclosure Agreement, hold it in escrow, and produce it to opposing counsel either prior to such person being permitted to testify (at deposition or trial) or at the conclusion of the case, whichever comes first.
+
+8. All Confidential Discovery Material filed with the Court, and all portions of pleadings, motions or other papers filed with the Court that disclose such Confidential Discovery Material, shall be filed under seal with the Clerk of the Court and kept under seal until further order of the Court. The parties will use their best efforts to minimize such sealing. In any event, any party filing a motion or any other papers with the Court under seal shall also publicly file a redacted copy of the same, via the Court's Electronic Case Filing system, that redacts only the Confidential Discovery Material itself, and not text that in no material way reveals the Confidential Discovery Material.
+
+9. Any party who either objects to any designation of confidentiality, or who, by contrast, requests still further limits on disclosure (such as "attorneys' eyes only" in extraordinary circumstances), may at any time prior to the trial of this action serve upon counsel for the designating person a written notice stating with particularity the grounds of the objection or request. If agreement cannot be reached promptly, counsel for all affected persons will convene a joint telephone call with the Court to obtain a ruling.
+
+10. All persons are hereby placed on notice that the Court is unlikely to seal or otherwise afford confidential treatment to any Discovery Material introduced in evidence at trial, even if such material has previously been sealed or designated as Confidential. The Court also retains unfettered discretion whether or not to afford confidential treatment to any Confidential Document or information contained in any Confidential Document submitted to the Court in connection with any motion, application, or proceeding that may result in an order and/or decision by the Court.
+
+II. Each person who has access to Discovery Material that has been designated as Confidential shall take all due precautions to prevent the unauthorized or inadvertent disclosure of such material.
+
+12. If, in connection with this litigation, a party inadvertently discloses information subject to a claim of attorney-client privilege or attorney work product protection, including any privilege or immunity from production associated with BSA, SAR-Related Information, and/or CSI ("Inadvertently Disclosed Information"), such disclosure shall not constitute or be deemed a waiver or forfeiture of any claim of privilege or work product or such other applicable protection with respect to the Inadvertently Disclosed Information and its subject matter. For avoidance of doubt, outside of authorization from an appropriate regulatory authority, the disclosure of BSA, SAR-Related Information and/or CSI shall not constitute or be deemed a waiver or forfeiture of any claim of privilege or work product or such other applicable protection with respect to such information.
+
+13. If a disclosing party makes a claim of inadvertent disclosure, the receiving party shall not thereafter review the Inadvertently Disclosed Information for any purpose, except by order of the Court. The receiving party shall, within five business days, return or destroy all copies of the Inadvertently Disclosed Information, and provide a certification of counsel that all such information has been returned or destroyed.
+
+14. Within five business days of the notification that such Inadvertently Disclosed Information has been returned or destroyed, the disclosing party shall produce a privilege log with respect to the Inadvertently Disclosed Information.
+
+15. As with any information redacted or withheld, the receiving party may move the Court for an Order compelling production of the Inadvertently Disclosed Information. The motion shall be filed under seal, and shall not assert as a ground for entering such an Order the fact or circumstances of the inadvertent production.
+
+16. The disclosing party retains the burden of establishing the privileged or protected nature of any Inadvertently Disclosed Information. Nothing in this Order shall limit the right of any party to request an in camera review of the Inadvertently Disclosed Information.
+
+17. This Protective Order shall survive the termination of the litigation. Within 30 days of the final disposition of this action, all Discovery Material designated as "Confidential," and all copies thereof, shall be promptly returned to the producing person, or, upon permission of the producing person, destroyed. For the avoidance of doubt, counsel of record in this action shall be permitted to keep copies of filings and work product that incorporates any Confidential Discovery Material, so long as counsel continues to treat such Confidential Discovery Material in accordance with this Order.
+
+18. This Court shall retain jurisdiction over all persons subject to this Order to the extent necessary to enforce any obligations arising hereunder or to impose sanctions for any contempt thereof.
+
+## SO STIPULATED AND AGREED.
+
+### BERNSTEIN LITOWITZ BERGER & GROSSMANN LLP
+
+#### /s/ Mark Lebovitch
+
+Mark Lebovitch (with permission) Sara Swartzwelder MarIcL@blbglaw.com sara.swartzwelder@blbglaw.com 1251 Avenue of the Americas New York, New York 10020 (212) 554-1400
+
+# BERNSTEIN LITOWITZ BERGER & GROSSMANN LLP
+
+Daniel Meyer 500 Delaware Avenue, Suite 901 Wilmington, DE 19801 daniel.meyer@blbglaw.com (212) 554-1400
+
+Counsel for Plaintiff City of Miami General Employees & Sanitation Employees Retirement Trust
+
+# GRANT & EISENHOFER P.A.
+
+# /s/ Rebecca A. Musarra
+
+Rebecca A. Musarra (with permission) J. Orrico Vivek Upadhya 485 Lexington Ave., 29th Floor New York, NY 10017 rmusarra®gelaw.com corrico®gelaw.com viipadhya@gelaw.com (646) 722-8500
+
+Michael J. Barry (admitted pro hac) Christine M. Mackintosh (admitted pro hac) 123 Justison St. Wilmington DE 19801 mbarry@gelaw.com cmackintosh®gelaw.com
+
+#### WILMER CUTLER PICKERING HALE AND DORR LLP
+
+#### /s/ Timothy Perla
+
+Timothy Perla (with permission) 60 State Street Boston, 02109 (t) (617) 526-6000 (f) (617) 526-5000 timothy.perla@wilmerhale.com
+
+Noah A. Levine 7 World Trade Center 250 Greenwich Street New York, NY 10007 (t) (212) 230-8800 (9 (212) 230-8888 noah.levine@wilmerhale.com
+
+Attorneys for Defendants JPMorgan Chase Co. and James Dimon
+
+## PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
+
+### /s/AudraI. Soloway
+
+Audra J. Soloway Jessica S. Carey Jacobus Schutte 1285 Avenue of the Americas New York, NY 10019 asoloway@paulweiss.com jcarey®paulweiss.com jschutte@paulweiss.com 212-373-3000
+
+Attorneys for Defendants Stephen B. , Todd A. Combs, James S. Crown, Timothy P. Flynn, Mellody Hobson, John W. Kessler, and Phebe N. Novakovic
+
+(302) 622-7000
+
+Counsel for Plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund
+
+Dated: July 6, 2023
+
+SO ORDERED.
+
+Dated:
+
+New York, New York
+
+/s/ John McNichols
+
+John McNichols (with permission)
+
+& CONNOLLY LLP
+
+680 Maine Avenue SW
+
+Washington, DC 20024
+
+Tel: (202) 434-5252
+
+Fax: (202) 434-5029
+
+jmcnichols@wc.com
+
+Counsel for Defendant James Edward Staley
+
+Dated: July 6, 2023
+
+JED S. RAKOFF, U.S.D.J.
+
+#### UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+Case No. 1:23-CV-03903 (JSR)
+
+DERIVATIVE ACTION
+
+## NON-DISCLOSURE AGREEMENT
+
+, acknowledge that I have read and understand the Protective Order in this action governing the nondisclosure of those portions of Discovery Material that have been designated as Confidential. I agree that I will not disclose such Confidential Discovery Material to anyone other than for purposes of this litigation and that at the conclusion of the litigation I will return all discovery information to the party or attorney from whom I received it, or confirm to that party or attorney that such information has been destroyed. By acknowledging these obligations under the Protective Order, I understand that I am submitting myself to the jurisdiction of the United States District Court for the Southern District of New York for the purpose of any issue or dispute arising hereunder and that my willful violation of any term of the Protective Order could subject me to punishment for contempt of Court.
+
+Dated:
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02823028/EFTA02823028.md b/marker2/court-pension-v-dimon/EFTA02823028/EFTA02823028.md
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+## I N T HE UNITED STATES DISTRICT COURT FOR "I'HE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JPMORGAN CHASE & CO. DERIVATIVE LITIGATION
+
+Case No. 1:23-cv-03903-JSR
+
+DERIVATIVE ACTION
+
+## DEFENDANT JAMES E. STALEY'S NOTICE OF MOTION TO DISMISS THE AMENDED STOCKTIOI R DERIVATIVE COMPLAINT
+
+Pursuant to Rules 12(IX6) and 23 1 (1) of the Federal Rules of Civil Procedure, Defendant James E. Staley hereby respectfully requests that the Court dismiss all claims in the Complaint filed by Plaintiffs on behalf of Nominal Defendant JPMorgan Chase & Co. The reasons supporting Mr. Staley's motion are set forth in the corresponding Memorandum of Law.
+
+In accordance with the Court's Case Management Plan, ECF No. 16, this response to Plaintiffs' Complaint is filed by July 6, 2023. Per the same order, Plaintiffs' response to this motion is due by July 20, 2023; and Defendants' reply briefs, if any, are due by July 29, 2023.
+
+Date: July 6, 2023 Respectfully submitted,
+
+/s/ John McNichols
+
+Brendan V. Jr.
+
+John McNichols
+
+Zachary
+
+S hen L. Wohlgemuth
+
+& CONNOLLY LLP 680 Maine Avenue SW
+
+Washington, DC 20024
+
+Tel: (202) 434-5252
+
+Fax: (202) 434-5029
+
+jmcnichols@wc.com
+
+Counsel for Defendant James Edward Staley
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+#### IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JPMORGAN CHASE & CO. DERIVATIVE LITIGATION
+
+=Case No. 1:23-cv-03903-JSR
+
+DERIVATIVE ACTION
+
+#### DEFENDANT JAMES E. STALEY'S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS COMPLAINT
+
+#### TABLE OF CONTENTS
+
+| PRELIMINARY STATEMENT                                                 |                                                                 |
+|-----------------------------------------------------------------------|-----------------------------------------------------------------|
+| BACKGROUND                                                            | 2                                                               |
+| A. Parties                                                            | 2                                                               |
+| B. The Alleged Wrongdoing                                             | 3                                                               |
+| C. Procedural History                                                 | 4                                                               |
+| ARGUMENT                                                              | 6                                                               |
+| I. Plaintiffs Have Failed To Show That Demand on the Board Is Excused | 6                                                               |
+| A.                                                                    | Plaintiffs Cannot Show Demand Futility as to Mr. Staley Because |
+| the Bank Has Already Sued Him on the Same Allegations                 | 8                                                               |
+| B. Plaintiffs' Allegations That the Board Could Not Impartially       |                                                                 |
+| Consider a Litigation Demand Fall Short                               | 8                                                               |
+| II. The Claims Against Mr. Staley Specifically Are Defective          | 15                                                              |
+| A. Plaintiffs Fail To State a Claim Against Mr. Staley                | 15                                                              |
+| B. The Claims Against Mr. Staley Are Time-Barred                      | 18                                                              |
+| III. Under the Doctrine of Claim Splitting, This Suit Cannot Proceed  |                                                                 |
+| Against Mr. Staley                                                    | 20                                                              |
+| CONCLUSION                                                            | 22                                                              |
+
+## TABLE OF AUTHORITIES
+
+## CASES
+
+| /n re Am. Int7 Op., Inc. Derivative Litig.,   | 415 F. App'x 285 (2d Cir. 2011)               | 8, 14          |
+|-----------------------------------------------|-----------------------------------------------|----------------|
+| Am. Exch., LLC v. Mopex,                      | /nc., 215 F.R.D. 87 (S.D.N.Y. 2002)           | 20             |
+| ex ret AmSouth Bancorporation v. Ritter,      | 911 A.2d 362 (Del. 2006) (en banc)            | 10             |
+| Aronson v. M,                                 | 473 A.2d 805 (Del. 1984)                      | 7              |
+| Ashcroft v. Iqbal,                            | 556 U.S. 662 (2009)                           | 15             |
+| Barclay v. Lowe,                              | 131 F. App'x 778 (2d Cir. 2005) (unpublished) | 21             |
+| Beam v. Stewart,                              | 833 A.2d 961 (Del. Ch. 2003)                  | 9              |
+| v. Breen,                                     | 2018 WL 565267 (S.D.N.Y. Jan. 23, 2018)       | 7              |
+| Busher v. Barry,                              | 2021 WL 5071871 (2d Cir. Nov. 2, 2021)        | 19             |
+| In re Caremark hal Inc. Derivative Litig.,    | 698 A.2d 959 (Del. Ch. 1996)                  | 10, II, 12, 16 |
+| Cent. Laborers' Pension Fund v. Dimon,        | 2014 WL 3639185 (S.D.N.Y. July 23, 2014)      | 6              |
+| Chapin v. Benwood Found., Inc.,               | 402 A.2d 1205 (Del. Ch. 1979)                 | 16             |
+| Coleman v. B.G. Sulde, Inc.,                  | 402 F. Supp. 2d 403 (N.D.N.Y. 2005)           | 21             |
+| Corsello v. Verizon New York Inc.,            | 18 N.Y.3d 777 (2012)                          | 20             |
+| Curtis v. Citibank, N.A.,                     | 226 F.3d 133 (2d Cir. 2000)                   | 20             |
+| In re Delta & Pine Land Co. S'holders Litig., | 2000 WL 875421 (Del. Ch. June 21, 2000)       | 8              |
+| DiRienzo v. Lichtenstein,                     | 2013 WL 5503034 (Del. Ch. Sept. 30, 2013)     | 13             |
+| In re Dow Chem. Co. Derivative Litig.,        | 2010 WL 66769 (Del. Ch. Jan. II, 2010)        | 13             |
+| Ellul v. Congregation of Christian Bros.,     | 774 F.3d 791 (2d Cir. 2014)                   | 18             |
+| Flannery v. Genomic Health, Inc.,             | 2021 WL 3615540 (Del. Ch. Aug. 16, 2021)      | 14             |
+| Franchi v. Firestone,                         | 2021 WL 5991886 (Del. Ch. May 10, 2021)       | 13             |
+| In re Gen. Motors Co. Derivative Litig.,      | 2015 WL 3958724 (Del. Ch. June 26, 2015)      | 11             |
+| Hilton Head Holdings b.v. v. Peck,            | 2012 WL 613729 (S.D.N.Y. Feb. 23, 2012)       | 18, 19         |
+
+| Norman v. Abney,                                                       | 2017 WL 242571 (Del. Ch. Jan. 19, 2017)   | 12     |
+|------------------------------------------------------------------------|-------------------------------------------|--------|
+| Hughes v. Xiaoming Hu,                                                 | 2020 WL 1987029 (Del. Ch. Apr. 27, 2020)  | 17     |
+| reL J.C. Penney Co., v. Ellison,                                       | 2019 WL 3408812 (Del. Ch. July 29, 2019)  | 11     |
+| Kamen v. Kemper Fin. Servs., Inc.,                                     | 500 U.S. 90 (1991)                        | 7      |
+| Kermanshah v. Kermanshah,                                              | 580 F. Supp. 2d 247 (S.D.N.Y. 2008)       | 18     |
+| Lambrecht v. O'Neal,                                                   | 504 F. App'x 23 (2d Cir. 2012)            | 9, 10  |
+| In re LendingClub Corp. Derivative Litig.,                             | 2019 WL 5678578                           | II     |
+| In re McDonald's Corp. S'holder Derivative Litig.,                     | 289 A.3d 343 (Del. Ch. 2023)              | II, 16 |
+| MCG Cap. Corp. v. Maginn,                                              | 2010 WL 1782271 (Del. Ch. May 5, 2010)    | 14     |
+| In re MetLife Inc. Derivative Litig.,                                  | 2020 WL 4746635 (Del. Ch. Aug. 17, 2020)  | 15     |
+| Nemec v. Shrader,                                                      | 991 A.2d 1120 (Del. 2010) (en bane)       | 18     |
+| 2017 WL 6452240 (Del. Ch. Dec. 18, 2017)                               |                                           | 12     |
+| 2023 WL 3093500 (Del. Ch. Apr. 26, 2023)                               |                                           | 16     |
+| Patel v. Duncan,                                                       | 2021 WL 4482157 (Del. Ch. Sept. 30, 2021) | 9      |
+| Petrosurance, Inc. v. Nat? Ass 'n of Ins. Comm 'rs,                    | 888 F. Supp. 2d 491 (S.D.N.Y. 2012)       | 16     |
+| In re Pfizer Inc. S'holder Derivative Litig.,                          | 722 F. Supp. 2d 453 (S.D.N.Y. 2010)       | 18     |
+| Melbourne Mun. Firefighters' Pension Tr. Fund ex reL Qualcomm, Inc. v. |                                           | IME,   |
+| 2016 WL 4076369 (Del. Ch. Aug. I, 2016)                                |                                           | 10     |
+| Reiter v. Fairbank,                                                    | 2016 WL 6081823 (Del. Ch. Oct. 18, 2016)  | 15     |
+| Ret. Sys. v. Carlson,                                                  | 2010 WL 2376890 (Del. Ch. June 7, 2010)   | 17     |
+| as Tr. of~                                                             | Living Tr. v. Clark,                      |        |
+| 2020 WL 7861335 (Del. Ch. Dec. 31, 2020)                               |                                           | 8      |
+| In re SAIC Inc. Derivative Litig.,                                     | 948 F. Supp. 2d 366 (S.D.N.Y. 2013)       | 7      |
+| Huck ex reL Sea Air Shuttle Corp. v. Dawson,                           | 106 F.3d 45 (3d Cr. 1997)                 | 21     |
+| Steinberg v. Dimon,                                                    | 2014 WL 3512848 (S.D.N.Y. July 16, 2014)  | 18     |
+
+United Food & Corn. Workers Union v. Zucker berg, 262 A.3d 1034 (Del. 2021) (en bane) 7, 8, 9, 13
+
+v. Baum, 953 A.2d 136 (Del. 2008) 7, 10
+
+Yucaipa Am. AIL Fund II, L.P. v. Riggio, 1 A.3d 310 (Del. Ch. 2010) 13
+
+## STATUTES
+
+8 Del. C. § 102(b)(7) 10
+
+8 Del. C. § 141 16
+
+N.Y. CPLR § 213(7) 18
+
+N.Y. CPLR § 213(8) 19
+
+N.Y. CPLR § 214(3) 18
+
+#### RULES
+
+Federal Rule of Civil Procedure 9(b) 1, 19
+
+Federal Rule of Civil Procedure 12(b)(6) I, 15, 18, 19
+
+Federal Rule of Civil Procedure 23.1 I, 7, 15
+
+## OTHER AUTHORITIES
+
+I 8A Charles Alan =, Arthur R. & Edward H. =, Federal Practice and Procedure § 4406 (3d ed.) 20
+
+Defendant James E. "Jes" Staley respectfully submits this Memorandum of Law in Support of his Motion To Dismiss the Verified Amended Consolidated Shareholder Derivative Complaint ("Complaint" or "Compl.") pursuant to Rules 9(b),12(6)(6), and 23.1 of the Federal Rules of Civil Procedure. Mr. Staley expressly adopts and incorporates by reference the arguments advanced in the Memorandum of Law in Support of Defendants' Motion To Dismiss the Complaint filed by JPMorgan Chase & Co. ("JPMorgan") and related Defendants on July 6, 2023. See ECF No. 25.
+
+## PRELIMINARY STATEMENT
+
+Plaintiffs allege that the directors and officers of JPMorgan, the nation's largest bank, failed to implement any compliance systems to review the bank's relationship with Jeffrey Epstein—the bank's most controversial client—and ignored countless red flags concerning his financial activities, ultimately harming the company after Epstein's criminal proclivities were exposed. One of the officers whom Plaintiffs have sued on this theory is Jes Staley, the former head of the bank's investment banking division, who left JPMorgan more than a decade ago. Plaintiffs' claims against Mr. Staley fail at the threshold for multiple reasons.
+
+Having declined to make a demand on the board before filing this derivative suit, Plaintiffs must show that JPMorgan's current board of directors could not be trusted to bring claims against its officers and directors. Plaintiffs cannot make this showing as to Mr. Staley, given that the bank—under the leadership of the very same board—already sued Mr. Staley earlier this year, in this very Court, on the same factual allegations. Moreover, the two claims against Mr. Staley (in Counts II and III) fail to state a claim because Plaintiffs fail to plead (i) any allegations that Mr. Staley actually owed the supervisory duties that they accuse him of breaching, or (ii) any basis to toll the statute of limitations for claims that accrued more a decade ago. Finally, the doctrine of claim splitting bars any repetitive claims against Mr. Staley by JPMorgan, which this derivative suit clearly is. The Court should dismiss the claims against Mr. Staley.
+
+#### BACKGROUND
+
+#### A. Parties
+
+Nominal Defendant JPMorgan Chase & Co. (as previously defined, "JPMorgan") is a Delaware corporation headquartered in New York, New York, that provides financial and investment services as the nation's largest banking institution. Compl. ¶ 32. Plaintiffs are two pension funds that currently hold JPMorgan common M, and which purport to bring derivative claims on JPMorgan's behalf. M.11 29-31.
+
+There are two sets of individual defendants in this case, the "Director Defendants" and the "Officer Defendants." JPMorgan's current CEO and Board Chairman James "Jamie" Dimon is sued in both capacities.
+
+Director Defendants. Stephen B. =, Todd A. Combs, James S. Crown, Timothy P. Flynn, Mellody Hobson, John W. Kessler, Phebe N. Novakovic, and Dimon are current or former directors of JPMorgan's board. Id. ¶¶ 33-39. All except Kessler were members of the so-called "Demand Board," i.e., the twelve-member Board of Directors tasked with managing the bank's affairs at the time this lawsuit was filed in May 2023. Id. ¶ 188.
+
+Officer Defendants. Besides Dimon, the only other Officer Defendant is Jes Staley, a former executive who left the bank in 2013 after serving as head of the firm's Investment Bank since 2009. Id. ¶ 42. Mr. Staley previously occupied several roles within the bank's Asset Management division, where he interacted with financier Jeffrey Epstein, a client of the bank. Id. ¶ 109. Mr. Staley never served on the company's Board of Directors. Id. ¶¶ 40, 42.
+
+Upon information and belief, Mr. Crown died on June 25, 2023, seven weeks after this suit was filed. See Suggestion of Death, ECF No. 23.
+
+#### B. The Alleged Wrongdoing2
+
+The allegations underlying this lawsuit are familiar to the Court. See Op. and Order, Jane Doe v. JPMorgan Chase Bank, N.A., 1:22-cv-10019-JSR, ECF No. 102; Op. and Order, Gov't of the U.S. Virgin Islands v. JPMorgan Chase Bank, N.A., 1:22-cv-10904-JSR, ECF, No. 130. As relevant here, the Plaintiff pension funds allege that Defendants facilitated a colossal breakdown in compliance and oversight requirements in JPMorgan's relationship with Jeffrey Epstein, resulting in harm to the bank.
+
+According to the Complaint, even before the bank first onboarded Epstein as a client in 1998, he was a well-known and controversial figure, and thus a "high-risk, but high-reward, client." Compl. ¶ 62. Such a client should have undergone robust due-diligence review, id. ¶¶ 63- 64, in part due to his notoriety and in part because—as a global financial institution—JPMorgan was subject to numerous laws and regulations requiring certain internal controls to monitor client activity, id. ¶¶ 49-60.
+
+The Complaint further alleges that, once onboarded as a client, Epstein should have received additional scrutiny from the bank, principally because of the well-publicized charges of sexual abuse that eventually led to his arrest, incarceration, and registration as a sex offender in 2008. Id. ¶¶ 113-33. Although the bank terminated Epstein as a client in 2013, id. ¶ 158, Plaintiffs allege that, for several years before then, JPMorgan ignored certain "red-flag" evidence of Epstein's possible sex trafficking, including (i) his prodigious cash withdrawals, (ii) his frequent transporting of women on international flights via private jet, and (iii) his suspicious foreign
+
+<sup>2</sup> Although he vigorously denies many of the allegations in this case, Mr. Staley treats as true the Complaint's factual allegations for purposes of this motion.
+
+remittances. Id. ¶¶ 145, 154, 159-69. According to the Complaint, JPMorgan failed to follow through on investigating such activity and reporting it to the authorities. Id. ¶¶ 154-62, 169.
+
+As to Mr. Staley specifically, the Complaint alleges that, at the very outset of the relationship, the bank tasked Mr. Staley with "managing Epstein as a client," and that over time, the two developed a personal friendship. Id. ¶¶ 109-10. Other executives and departments of JPMorgan, however, were aware of and responsible for keeping tabs on Epstein's activities and the risks he posed to the bank. Id. ¶¶ 5, 146-47, 149-55.
+
+# C. Procedural History
+
+On November 24, 2022, "Jane Doe"—a purported victim of Epstein's trafficking—sued JPMorgan on putative class claims for negligence and violation of the Trafficking Victims Protection Act. See Compl., Jane Doe v. JPMorgan Chase Bank, N.A., 1:22-cv-10019-JSR, ECF No. 1. The U.S. Virgin Islands similarly sued the bank a few weeks later. Compl., Gov't of the U.S. Virgin Islands v. JPMorgan Chase Bank, N.A., 1:22-cv-10904-JSR, ECF No. I. JPMorgan subsequently impleaded Mr. Staley into both cases, suing him for, inter alia, (i) breach of his fiduciary duties, and (ii) violation of the "faithless servant" doctrine, based on alleged misconduct in Mr. Staley's interaction with Epstein as a client. See Third-Party Compls., ECF Nos. 59, 130. The litigation between JPMorgan and Mr. Staley remains ongoing.
+
+In May 2023—roughly six months after the above-mentioned Jane Doe lawsuit—the first pension fund Plaintiff filed this derivative action. (Initial) Compl., ECF No. I. The second Plaintiff filed suit roughly six weeks later, and—following consolidation—the two funds jointly filed the operative Amended Complaint on June 30, 2023. ECF No. 17. The Amended Complaint asserts three causes of action: (i) breach of fiduciary duty against the Director Defendants (Count I), (ii) breach of fiduciary duty against the Officer Defendants (Count II), and unjust enrichment
+
+against both Defendant groups (Count III). Complin 200-20. As to all three Counts, the crux of the allegations is that Defendants—including Mr. Staley—breached their fiduciary duties to JPMorgan by "ignoring red flags related to Epstein's actions and failing to adhere to their own internal controls," or "knowingly disregarding their own internal controls," such that Epstein's activities continued uninterrupted, and the bank later suffered financial and reputational damages as a result of its commercial relationship with him. Id. ¶¶ 211-13. Plaintiffs acknowledge that these alleged failings occurred more than a decade ago, but suggest that the untimeliness of their lawsuits can be excused by "concerted and long-running efforts to conceal critical facts" by unnamed individuals at JPMorgan. Id. 1 197.
+
+Although Plaintiffs filed derivatively on behalf of Nominal Defendant JPMorgan, neither pension fund made a pre-suit demand on the Board, and instead they contend that demand should be excused as futile. Id. ¶ 185. In this regard, the Demand Board—i.e., the persons who would have received and considered a demand, had Plaintiffs made one—consisted of twelve members, seven of whom are Defendants: Combs, Crown, Dimon, Flynn, Hobson, and Novakovic; and five of whom are not: Linda B. Bammann, Alicia Boler MI, Alex Gorsky, Michael A. Neal, and Virginia Rometty. Id. ¶ 188.
+
+Plaintiffs concede that three of the twelve Demand Board members—M, Gorsky, and Rometty—face no conflicts and are thus independent for purposes of assessing litigation demands. Id. ¶¶ 189-92. For the remaining members, Plaintiffs predictably allege that all seven Defendant members of the Demand Board are biased due to their own potential liability on the claims at issue. Id. ¶ 189. Plaintiffs state that Michael Neal faces "a substantial likelihood of liability" in this action or related actions, but he is not a defendant and there is no further explanation. Id.
+
+The Complaint also alleges a lack of independence, contending that non-defendant director Bammann is not independent from Dimon because she "owes a significant portion of her professional success" to him based on (i) her previous work roles under him at Bank One from 2001 to 2004 and at JPMorgan in 2005, and (ii) the fact that she joined JPMorgan's board when he was chairman. Id. ¶ 193. The Complaint similarly contends that Defendant Crown, too, lacks independence from Dimon because he (i) served on the board of directors at Bank One while Dimon was its CEO, and (ii) later "advocated" for Dimon to assume a leadership role at JPMorgan. Id. ¶ 194. Defendant Novakovic, in turn, is allegedly not independent from Crown because she is currently CEO and Chair of General Dynamics, which is "Crown's family business." Id. ¶ 195.
+
+#### ARGUMENT
+
+Mr. Staley is a Defendant as to Counts II and III of the Complaint. Both claims are fatally deficient for multiple reasons. First, Plaintiffs do not (and cannot) show that making a demand of JPMorgan's board would have been futile given that the company is already suing Mr. Staley in this very Court. Nor do Plaintiffs meet their high burden to show that the board lacks impartiality to weigh litigation against all Defendants generally. Second, the claims against Mr. Staley are substantively deficient because they fail to allege (i) any basis to conclude that Mr. Staley had the supervisory duties that they accuse him of breaching, or (ii) any basis to toll the expired limitations periods on claims that accrued long ago under New York law. Lastly, the doctrine of claim splitting bars the repetitive claims against Mr. Staley by JPMorgan that this suit seeks to advance.
+
+## I. Plaintiffs Have Failed To Show That Demand on the Board Is Excused.
+
+It is a "'cardinal precept" of Delaware lawl that "directors, rather than shareholders, manage the business and affairs of the corporation," including by deciding whether and whom to
+
+<sup>3</sup> "In determining whether demand is required or excused, the Court applies the substantive law of Delaware, JPMorgan's state of incorporation." Cent. Laborers' Pension Fund v. Dimon, 2014 WL
+
+sue for alleged harm to the business. United Food & Com. Workers Union v. Zuckerberg, 262 A.3d 1034, 1047 (Del. 2021) (en bane) (quoting Aronson v. 473 A.2d 805, 811 (Del. 1984)). Because a derivative suit "encroaches on the managerial freedom of directors," id., Federal Rule of Civil Procedure 23.1 requires that a stockholder bringing such a suit either (1) make a demand on the board, or (2) show why a demand would be futile. Id. This demand requirement "is not excused lightly," id. at 1049, and a complaint must "state with particularity" the reasons for not obtaining the board's approval "or not making the effort." Fed. R. Civ. P. 23.1(bX3). As courts have observed, this is an "atypically rigorous" pleading requirement, In re WC Inc. Derivative Litig., 948 F. Supp. 2d 366, 384 (S.D.N.Y. 2013), affd, 553 F. App'x 54 (2d Cir. 2014), so "surviving a motion to dismiss for failure to comply with Rule 23.1 is a difficult feat." v. Breen, 2018 WL 565267, at \*5 (S.D.N.Y. Jan. 23, 2018) (internal quotation and citation omitted).
+
+Where, as here, a plaintiff admits that it made no demand of the board but alleges that its failure to do so may be excused as futile, its pleadings must show that the current board of directors was "incapable of making an impartial decision regarding the pursuit of the litigation." v. Baum, 953 A.2d 136, 140 (Del. 2008). This showing requires a well-supported rationale as to why the board could not be relied on to press claims aggressively against the would-be defendants, such as that certain members of the board would face a personal risk of liability in the litigation, or would be "beholden" to those who would. As explained below, Plaintiffs cannot make the required showing here.
+
+<sup>3639185,</sup> at \*2 (S.D.N.Y. July 23, 2014), aff'd, 638 F. App'x 34 (2d Cir. 2016); see Kamen v. Kemper Fin. Servs., Inc., 500 U.S. 90, 108-09 (1991).
+
+#### A. Plaintiffs Cannot Show Demand Futility as to Mr. Staley Because the Bank Has Already Sued Him on the Same Allegations.
+
+The Court need not undertake a standard demand-futility analysis here because there can be no doubt of the Demand Board's ability—and willingness—to sue Mr. Staley for the events at issue. As this Court is well aware, JPMorgan has already sued Mr. Staley for breach of fiduciary duty based on the identical alleged acts underlying this derivative action. See Third-Party Compls., Doe v. JPMorgan, 1:22-cv-10019-JSR, ECF No. 59; USVI v. JPMorgan, 1:22-cv-10904-JSR, ECF, No. 130. Indeed, the bank did so less than four months ago, and no director left or joined the company's board since Plaintiffs initiated this suit. See generally Comp1.1 33-39, 188.
+
+In short, the very same Demand Board that Plaintiffs declined to petition has already done what Plaintiffs claim it would never do if asked. For that reason alone, Plaintiffs' failure to make that demand cannot be excused. See, e.g., In re Delta & Pine Land Co. S'holders Litig., 2000 WL 875421, at \*6 (Del. Ch. June 21, 2000) ("[T]he existence of a board-initiated action conclusively defeats any claim that demand would have been futile."); as Tr. of Living Tr. v. Clark, 2020 WL 7861335, at \*12 (Del. Ch. Dec. 31, 2020) (dismissing claim where the "Demand Board would . .. have been able to apply its business judgement to a demand").
+
+## B. Plaintiffs' Allegations That the Board Could Not Impartially Consider a Litigation Demand Fall Short.
+
+Under a standard demand-futility analysis, a court presumes that directors are independent and faithful to their fiduciary duties, In re Am. Intl Grp., Inc. Derivative Litig., 415 F. App'x 285, 286 (2d Cir. 2011), and thus to show futility, a plaintiff must establish one of the following three things for at least half the members of the demand board: (1) that the member "received a material personal benefit" from the misconduct alleged in the lawsuit; (2) that he "faces a substantial likelihood of liability" on a particular claim; or (3) that he "lacks independence" from someone who meets one of the first two criteria. Zuckerberg, 262 A.3d at 1058 (adopting three-prong test); see also Patel v. Duncan, 2021 WL 4482157, at \*18 (Del. Ch. Sept. 30, 2021) (confirming Zuckerberg test), afd, 227 A.3d 1257 (Del. 2022). And because futility is assessed "on a claimby-claim basis," Lambrecht v. O'Neal, 504 F. App'x 23, 26 (2d Cir. 2012); accord Beam v. Stewart, 833 A.2d 961, 977 n.48 (Del. Ch. 2003), afrd, 845 A.2d 1040 (Del. 2004), a plaintiff must make this showing independently for each claim at issue.
+
+Here, Plaintiffs make no allegation of a "material personal benefit" to any director,' so to establish futility as to both Counts II and III against Mr. Staley, they appear to rely exclusively on prongs two and three of the test from Zuckerberg identified above. They do not succeed.
+
+# I. Demand Is Not Excused for Claim II.
+
+Count II is a claim for breach of fiduciary duty against Mr. Staley and Dimon, alleging that, in their capacity as "Officers" of JPMorgan, they ignored red flags related to Epstein's banking activity and permitted the bank to neglect its reporting and compliance requirements. Compl. 11 208-15. As to this claim, Plaintiff's make no showing of demand futility on any of the available Zuckerberg grounds.
+
+Zuckerberg Prong Two: The second Zuckerberg prong hinges on a director facing a "substantial likelihood" of personal liability were his company to bring the claim at issue. Here, for Count II, the only persons whose conduct are at issue are Dimon and Mr. Staley, the "Officer Defendants." Compl. 9 208-15. Of those two, only Dimon sits on the Demand Board. None of remaining eleven members of the Board faces any liability on Count II, much less "a substantial likelihood of liability" as the law requires to show demand futility. 262 A.3d at 1058. So a clear
+
+<sup>4</sup> Indeed, several of the Demand Board members joined the board only after the bank terminated Epstein as a client, and thus they could not have benefited from any alleged actions by Dimon or Mr. Staley to conceal Epstein's dealings over the course of bank's relationship with him. See, e.g., Compl. 11 37 (Combs joining 2016), 38 (Hobson joining 2018), 190 (Neal joining after 2013), 35 (Novakovic joining 2020).
+
+majority of the board directors could fairly assess a litigation demand against the Officer Defendants, as articulated in Count II of the Complaint. See Melbourne Mun. Firefighters' Pension Tr. Fund ex rel. Qualcomm, Inc. v. 2016 WL 4076369, at •13 (Del. Ch. Aug. I, 2016) ("It is unclear ... how a majority of the Board could face a substantial likelihood of liability as to Count II when only two of the fifteen members of the Board . . . are included as Officer Defendants."), aff'd, 158 A.3d 449 (Del. 2017) (unpublished table decision).
+
+Although the Court should not consider the board members' potential liability on Count I when assessing demand futility as to Count 11,5 Plaintiffs' allegations of futility would still fall short even if the Court were to do so. Because JPMorgan has adopted the exculpatory protections of Section 102(bX7) of the Delaware General Corporation Law,' the company's directors face liability only for bad faith or disloyal conduct—e.g., knowingly engaging in illegal activity—not mere misjudgment or poor performance. ex rel. AmSouth Bancorporation v. Ritter, 911 A.2d 362, 367 (Del. 2006) (en bane); M, 953 A.2d at 141. To establish director liability under this standard, Plaintiffs attempt to plead a Caremark theory based on the directors' knowing abdication of oversight duties,7 which requires particularized facts showing that the directors either (1) "utterly failed to implement any reporting or information system or controls," or (2) after implementing such controls, "consciously failed to monitor or oversee [their] operations." M,
+
+<sup>5</sup> As noted above, futility is a claim-by-claim determination. Lambrecht, 504 F. App'x at 26.
+
+<sup>6</sup> See 8 Del. C. § I02(b)(7). "A serious threat of liabilit ma only be found to exist if the plaintiff pleads a non-exculpated claim against the directors." =953 A.2d at 141; see Decl. of Audra J. Soloway, Ex. 2 at 4, ECF No. 26-1 (exculpating directors to "the fullest extent" permitted by Delaware law for breaches of fiduciary duty).
+
+<sup>&#</sup>x27; The Director Defendants breached their fiduciary duties "either by ignoring red flags related to Epstein's actions and failing to adhere to their own internal controls or by knowingly disregarding their own internal controls and intentionally allowing the Company to continue facilitating Epstein's criminal conduct." Compl. 1 204.
+
+911 A.2d at 370 (emphases added); see also In re McDonald's Corp. S 'holder Derivative Litig., 289 A.3d 343, 359-60 (Del. Ch. 2023) (distinguishing an "Information-Systems" Caremark claim from a "Red-Flags" claim). Such a claim has been described as "possibly the most difficult theory in corporation law upon which a plaintiff might hope to win a judgment," and Plaintiffs' pleadings do not come close to satisfying the requirements. In re Caremark Int? Inc. Derivative Litig., 698 A.2d 959, 967 (Del. Ch. 1996).8
+
+First, while the Complaint faults the Director Defendants for failing to install "an adequate oversight system" to ensure compliance, Compl. ¶ 180, this is not equivalent to alleging that the directors undertook no efforts at all, as the law requires. ex rel. J.C. Penney Co., v. Ellison, 2019 WL 3408812, at \*9 (Del. Ch. July 29, 2019) (noting that "utterly" is a "linguistically extreme formulation"). Indeed, the Complaint admits that JPMorgan had a "compliance team" that "repeatedly flagged" Epstein's suspicious activity, bringing them to the attention of leixecutives at the highest reaches" of the bank. Compl. ¶ 181. Thus, Plaintiffs' grievances boil down to chides about the sufficiency of JPMorgan's internal controls, e.g., ¶¶ 149, 154, 158, 169, not their existence. This is a fatal failing, as courts routinely reject failure-of-oversight claims where, as here, a plaintiff acknowledges that the company had a regular compliance structure. See, e.g., In re Gen. Motors Co. Derivative Litig., 2015 WL 3958724, at \*14 (Del. Ch. June 26, 2015) (rejecting Caremark claim because company "had a system for reporting risk to the Board, but in [plaintiff's] view it should have been a better system"), affd, 133 A.3d 971 (Del. 2016); In re LendingClub
+
+<sup>8</sup> Such a showing is all the more difficult for director Michael Neal: Plaintiffs suggest that he could face substantial liability in this action or the Doe and USVI actions, Compl. ¶ 189, but he has not been sued in any case, and he did not even join the JPMorgan board until after the bank terminated Epstein as a client, id. ¶ 190.
+
+Corp. Derivative Litig., 2019 WL 5678578, at •9 n.59 & \*18 (Del. Ch. Oct. 31, 2019) (dismissing Caremark claim because company had, inter alia, risk and audit committees).
+
+Plaintiffs fare no better on Caremark's alternative theory of knowingly disregarding clear red flags. Under this "Red-Flags" theory, liability exists only when "the directors were conscious of the fact that they were not doing their jobs." Honnan v. Abney, 2017 WL 242571, at \*10 (Del. Ch. Jan. 19, 2017). Here, although the Complaint pleads a litany of alleged red flags (and ensuing management failures) in JPMorgan's compliance and anti-money laundering systems, e.g., Compl. fl 170-73, it is devoid of allegations of particularized knowledge or bad faith—i.e., "actual scienter"—by the individual directors who oversaw the bank. Okla. Firefighters Pension & Ret. Sys. v. Corbat, 2017 WL 6452240, at \*1 (Del. Ch. Dec. 18, 2017).9 Such conclusory allegations are insufficient, as Delaware courts reject the idea that "because illegal behavior occurred, internal controls must have been deficient, and the board must have known so." Norman, 2017 WL 242571, at •7 (emphasis added) (citation omitted). As these cases recognize, even wellintentioned oversight cannot guarantee a company's law-abiding behavior—especially when the company is the largest bank in the United States—and thus showing merely "that corporate wrongdoing has occurred" does not equate to showing that "directors failed to act in good faith." Id. But that is precisely the logic of Plaintiffs' allegations here. Compl. 1 189.'°
+
+<sup>9</sup> Perhaps that silence is strategic. After all, if Plaintiffs added factual allegations pertaining to each director—as it should to maintain a viable Caremark claim—then Plaintiff would find itself with a numbers problem. Of the twelve members of the Demand Board, at most five served on the Board while Epstein was a client of the bank. Compl. 1 190. They are thus the only Demand Board members who could conceivably face liability under a Caremark theory for "consciously disregarding" red flags about Epstein banking activities at JPMorgan.
+
+I° Plaintiffs' slapdash pleading is most evident in their decision to include Phebe Novakovic as a Director Defendant. Ms. Novakovic plainly could not have "ignor[edj red flags related to Epstein's actions" or "knowingly . . . allow[ed] the Company to continue facilitating Epstein's criminal conduct," Compl. 1 204, given that she did not join JPMorgan's board until 2020, after
+
+Zuckerberg Prong Three: The Complaint devotes a few lines to the idea that three Demand Board members-Bammann, Crown, Novakovic—lack independence because they are or were beholden to Jamie Dimon. The arguments cannot withstand scrutiny. Although it is true that Bammann worked under Dimon for five years, she did so nearly 20 years ago. Compl. ¶ 193. And while Crown worked with Dimon at Bank One—and helped select him for a leadership role at JPMorgan—he did so as a director serving over Dimon. not in a manner that would make Crown beholden. Id. ¶ 194. Such prior business relationships "fall well short of what is required under Delaware law to establish that a director lacks independence." DiRienzo v. Lichtenstein, 2013 WL 5503034, at •23 (Del. Ch. Sept. 30, 2013) (rejecting allegations that director served on board of defendant's outside portfolio companies); Franchi v. Firestone, 2021 WL 5991886, at ■5 **(Del. Ch. May 10, 2021) (director's nomination to other boards by defendant did not destroy independence). As one court has observed, the fact that directors of one company are also "colleagues at another institution does not mean that they will not or cannot exercise their own business judgment" when one or the other of them stands to lose or gain. In re Dow Chem. Co. Derivative Litig., 2010 WL 66769, at \*9 (Del. Ch. Jan. 11, 2010). A fortiori, when two colleagues' working relationship occurred a decade or more ago—as with Bammann and Dimon—inferring partiality is even less appropriate. See Yucaipa Am. All. Fund II. L.P. v. Riggio, 1 A.3d 310, 315 (Del. Ch. 2010) (rejecting lack-of-independence allegation based on director's work as defendant's subordinate ten years prior), aff'd, 15 A.3d 218 (Del. 2011) (unpublished table decision).** 
+
+**The Complaint fares no better impugning the independence of Novakovic. Plaintiffs' allegations of her partiality are entirely derivative of their arguments as to Crown. Compl. 1 195.** 
+
+**Epstein was already dead. Id. ¶ 36. While Plaintiffs have leveled serious allegations, they have not filed a serious complaint.** 
+
+That is, there is no allegation that Novakovic was herself beholden to Dimon—much less to Mr. Staley—but rather that she presently serves as CEO and Chair of "Crown's family business," and thus Crown's purported beholdenness should be attributed to her as well. Id. at 195 ("Crown likely has the influence to fire Novakovic."). I But even if Crown faced liability or his independence were somehow compromised—and, as noted above, neither is true—Plaintiffs' claims as to Novakovic would still amount to nothing more than speculation, falling well short of overcoming the strong presumption that directors operate independently and faithfully in their fiduciary duties. See In re Am. Intl Grp.. Inc. Derivative Litig., 415 F. App'x at 286. Indeed, the Complaint fails to plead whether Crown's role at General Dynamics gave him "'unilateral power,' much less substantial sway, over [Novakovic's] compensation or future job prospects," which is what the law requires to establish a lack of independence. Flannery v. Genomic Health, Inc., 2021 WL 3615540, at \*15 (Del. Ch. Aug. 16, 2021).
+
+## 2. Demand Is Not Excused for Count III.
+
+Aside from their claim in Count II for breach of fiduciary duty, Plaintiffs have also pleaded a claim against Mr. Staley in Count III for unjust enrichment. Compl. ¶¶ 216-20. Like all derivative claims, Count III must meet the same demand requirements as Count II. So, for demand to be excused as futile, Plaintiffs must show, as to Count Ill specifically, that the board could not consider the claim impartially. See MCG Cap. Corp. v. Maginn, 2010 WL 1782271, at \*23-24 (Del. Ch. May 5, 2010) (dismissing derivative claim for unjust enrichment because demand was not excused as futile).
+
+<sup>&</sup>quot; What Plaintiffs casually call "Crown's family business" is in fact General Dynamics—a publicly traded Fortune 100 company with no controlling shareholder.
+
+For the same reasons discussed above, Plaintiffs cannot make this showing. Count III differs from Count II only in that it is nominally a claim for unjust enrichment. Comp!. ¶ 218. But Plaintiffs' actual underlying theory of unjust enrichment—i.e., their basis to claim that Mr. Staley now possesses wealth that he should not have—depends entirely, and expressly, on their allegation that he breached his fiduciary duties to JPMorgan. In Plaintiffs' own words:
+
+> It would be unconscionable and against fundamental principles of justice, equity, and good conscience for the Individual Defendants to retain the benefits that they received only by virtue of breaching their fiduciary duties.
+
+Id. ¶ 219. Thus, the demand-futility showing fails for the same reasons. See Reiter v. Fairbank, 2016 WL 6081823, at \*14 (Del. Ch. Oct. 18, 2016) (dismissing derivative breach of fiduciary duty and unjust enrichment claims under Rule 23.1); see also In re MetLife Inc. Derivative Ling., 2020 WL 4746635, at \*18 (Del. Ch. Aug. 17, 2020) ("A Rule 23.1 analysis for the unjust enrichment claim thus necessarily treads the same path as the demand futility analysis, implicates the same conduct, and, therefore, obtains the same result." (cleaned up)).
+
+# II. The Claims Against Mr. Staley Specifically Are Defective.
+
+Besides their failure to establish demand futility, Plaintiffs' claims against Mr. Staley in Counts II and III are also fatally deficient for (i) failure to state a claim, and (ii) untimeliness under New York's statute of limitations.
+
+## A. Plaintiffs Fail To State a Claim Against Mr. Staley.
+
+Under Federal Rule of Civil Procedure 12(b)(6), "a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal quotation marks omitted). "A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Id. While the Court must draw all reasonable inferences in the complaint's favor, it need not accept as true "mere conclusions of
+
+law or unwarranted deductions of fact." Petrosurance, Inc. v. Nat'l Ass 'n of Ins. Comm 'rs, 888 F. Supp. 2d 491, 502 (S.D.N.Y. 2012) (internal quotation marks omitted).
+
+As noted above, Count II alleges that Officer Defendants Dimon and Staley breached their fiduciary duties to JPMorgan by "ignoring red flags related to Epstein's actions and failing to adhere to their own internal controls or by knowingly disregarding their own internal controls." Compl. ¶¶ 211-12. As applied to Mr. Staley specifically—who was never a director, but only an officer—this claim falters on the well-settled principle that, unlike directors, who bear "ultimate responsibility" for the entire business, 12 a corporate officer is merely an agent possessing only those powers and responsibilities delegated by the board. In re McDonald's, 289 A.3d at 369. While a company's CEO and Chief Compliance Officer may have "company-wide oversight portfolios," other officers "generally have a more constrained area of authority," which necessarily entails limitations on the duties that they owe. Id. Accordingly, where, as here, a plaintiff brings a Caremark breach-of-fiduciary duty claim against an officer, he must allege specific facts establishing that the officer-defendant owed oversight duties as to the particular corporate function where supervision allegedly broke down. See id. at 369-70 (ruling duty limited to "addressing or reporting red flags within [the officer's] areas of responsibility"); cf. Ontario Provincial Council of Carpenters' Pension Tr. Fund v. Walton, 2023 WL 3093500, at \*51 (Del. Ch. Apr. 26, 2023) (permitting Caremark claim because defendants "were Walmart's principal compliance officers ... during the actionable period") (emphasis added)).
+
+This principle defeats Plaintiffs' attempt to plead claims against Mr. Staley. Although Plaintiffs indiscriminately allege that the "Officer Defendants" were required to implement and
+
+<sup>12</sup> Chapin v. Ben wood Found., Inc., 402 A.2d 1205, 1211 (Del. Ch. 1979), aff'd sub nom. v. Chapin, 415 A.2d 1068 (Del. 1980); see 8 Del. C. § 141.
+
+maintain controls with respect to suspicious financial transactions and Know-Your-Customer regulations, e.g., Compl. ¶ 211, they fail to allege any area-specific oversight obligations of Mr. Staley, and make no showing whatsoever that the compliance function was ever within Mr. Staley's purview. In this regard, the Amended Complaint is replete with references to the bank's "risk management division," "compliance department," "compliance team," and even its "Global Corporate Security Division," id. 1115, 147, 151, 181, all without a single allegation that Mr. Staley either worked in or oversaw any of them. Unlike his co-Defendant Jamie Dimon—whose writ, as CEO, presumably ran the gamut—Mr. Staley served in discrete roles lower in the corporate hierarchy. And starting in 2009, Mr. Staley moved to JPMorgan's investment banking division, with no job duties connected to the bank's private wealth arm that handled Epstein's finances. Moreover, while Plaintiffs allege that Mr. Staley was tasked early on with securing Epstein as a client, they concede that the "top-level due diligence review" for onboarding him—i.e., the part of the process where, according to Plaintiffs, the breakdown in controls occurred—was undertaken by other employees. Id. ¶¶ 119, 122.
+
+Plaintiffs' unjust enrichment claim against Mr. Staley in Count III fares no better. As noted above, that claim expressly depends on the allegation that Defendants "breached their fiduciary duties," id. ¶ 217, and thus it necessarily fails for the same reasons. See, e.g., Monroe Cmy. Emps. ' Ret. Sys. v. Carlson, 2010 WL 2376890, at \*2 (Del. Ch. June 7, 2010) (dismissing unjust enrichment claim based on deficient fiduciary duty claim); Hughes v. Xiaoming Ku, 2020 WL 1987029, at •17 (Del. Ch. Apr. 27, 2020) (explaining that "unjust enrichment" is "properly conceived as a form of additional damages dependent on the plaintiff proving the oversight claim"). Even on its terms, moreover, the claim is fatally deficient. Under Delaware law, unjust enrichment requires a plaintiff to plead, among other things, "the absence of a remedy provided
+
+by law." Nemec v. Shrader, 991 A.2d 1120, 1130 (Del. 2010) (en bane). Even with the most generous reading, Plaintiffs nowhere pled that prerequisite. See id. at 1130-31 (affirming dismissal on that basis). In addition, the only damages that Plaintiffs claim are the Defendants' "profits, benefits, and other compensation," e.g., their salaries and bonuses. Compl. ¶ 217. As a matter of law, this is insufficient for an unjust enrichment claim:
+
+> [A] claim for unjust enrichment cannot be maintained where, as here, the "only enrichment alleged by plaintiffs consists of defendants' salaries, benefits, and unspecified bonuses."
+
+Steinberg v. Dimon, 2014 WL 3512848, at •4 (S.D.N.Y. July 16, 2014) (quoting In re Pfizer Inc. S'holder Derivative Litig., 722 F. Supp. 2d 453, 465 (S.D.N.Y. 2010)).
+
+## B. The Claims Against Mr. Staley Are Time-Barred.
+
+Even if Plaintiffs' claims against Mr. Staley were not substantively deficient, they would still fail as untimely." In New York, a six-year limitations period governs suits by corporations against their officers for mismanagement, which includes derivative suits for breaches of fiduciary duty. Hilton Head Holdings b.v. v. Peck, 2012 WL 613729, at •3 (S.D.N.Y. Feb. 23, 2012); see N.Y. CPLR § 213(7). And a three-year limitations period covers unjust enrichment claims where, as here, the plaintiff seeks monetary damages. Kermanshah v. Kermanshah, 580 F. Supp. 2d 247, 263 (S.D.N.Y. 2008); N.Y. CPLR § 214(3). Under either limit, Plaintiffs' claims against Mr. Staley are time-barred. Mr. Staley left his employment at the bank in January 2013, and Epstein was terminated as a client later the same year. Comp!. ¶¶ 42, 158. By that point—i.e., a full decade ago—any oversight duties that Mr. Staley owed came to an end, and any alleged breaches of those duties had already occurred. No related failures could conceivably have occurred
+
+<sup>13</sup> A "statute of limitations defense may be decided on a Rule I2(bX6) motion if the defense appears on the face of the complaint." Ellul v. Congregation of Christian Bros., 774 F.3d 791, 798 n.12 (2d Cir. 2014).
+
+thereafter. Because a claim "accrues upon the occurrence of the alleged wrongful act giving rise to restitution," Busher v. Barry, 2021 WL 5071871, at \*3 (2d Cir. Nov. 2, 2021) (citation omitted), both the three- and six-year limitations periods had long since expired when Plaintiffs filed this suit in May 2023.14
+
+Apparently anticipating this problem, Plaintiffs attempt to plead a tolling theory premised on fraudulent concealment, specifically that JPMorgan employees failed to disclose the "critical facts necessary to put Plaintiffs on notice." Comp!. ¶ 197. But under New York law, this theory applies only where a plaintiff shows that he (i) "was induced by fraud, misrepresentations or deception to refrain from filing a timely action," and (ii) that he undertook "reasonable reliance on the defendant's misrepresentations." Busher, 2021 WL 5071871, at \*4.15 In this regard, the best that Plaintiffs can do is to point to the failure of "the Company"—not Mr. Staley or any other Defendant—to file Suspicious Activity Reports "concerning Epstein and his accounts."16 Compl. ¶ 197. Even if this were true—and it is not"—it is emphatically not a failing that may be attributed
+
+<sup>14</sup> To be sure, for causes of action "based upon fraud," the limitations in Section 213(8) apply, including the extension until two years after "the plaintiff or the person under whom the plaintiff claims discovered the fraud, or could with reasonable diligence have discovered it." N.Y. CPLR. § 213(8). But Plaintiffs' claims here—alleging oversight and compliance failures—are not grounded in fraud. See Hilton Head Holdings, 2012 WL 613729, at \*3.
+
+<sup>15</sup> The federal doctrine of equitable tolling is unavailable for state causes of action in New York, so New York's tolling laws apply. Busher, 2021 WL 5071871, at \*4.
+
+<sup>16</sup> Although Plaintiffs make the entirely conclusory claim that Mr. Staley and others "actively concealed concerns," Compl. ¶ 198, this Court need not credit wholly unsupported allegations that merely mimic the legal standard but provide none of the detail required to satisfy Rule 9(b).
+
+<sup>17</sup> As mentioned, on a motion to dismiss pursuant to Rule 12(b)(6), the court can judicially notice information outside the pleadings, including in related court filings, when such information bears on notice for purposes of a tolling argument countering a statute of limitations defense. So the Court can note that the bank in fact filed numerous SARs related to Epstein, including "multiple suspicious activity reports related to Epstein's accounts in 2002." Op. and Order Granting Mot. for Class Certification at 5, Doe v. JPMorgan, 22-cv- I 0019-JSR, ECF No. 171. That fact destroys Plaintiffs' main theory here.
+
+to Mr. Staley, who had no responsibility for such filings nor any corporate authority to influence whether or not they were filed. Even more fundamentally, inaction—which is all that a failure-tofile amounts to—is not an affirmative act of concealment for purposes of a tolling argument, and New York law requires "an act of deception, separate from the ones for which" a plaintiff sues, as a basis for tolling. Corsello v. Verizon New York, Inc., 18 N.Y.3d 777, 789 (2012). The Complaint, moreover, contains no explanation as to why or how any actions affected Plaintiffs' ability or decision to sue, such as how they relied on particular filings (or the absence thereof) or how they were prevented from learning or doing anything. There is thus no basis for tolling the statute of limitations here.
+
+## III. Under the Doctrine of Claim Splitting, This Suit Cannot Proceed Against Mr. Staley.
+
+The Court should also dismiss the claims against Mr. Staley under the doctrine of claim splitting. This doctrine enforces the common-law rule that "a party must bring in one action all legal theories arising out of the same transaction or series of transactions." Am. Exch., LLC v. Moper, Inc., 215 F.R.D. 87, 91 (S.D.N.Y. 2002) (emphasis added); see also 18A Charles Alan Arthur R. & Edward H. =, Federal Practice and Procedure § 4406 (3d ed.) ("In dealing with simultaneous actions on related theories, courts at times express principles of `claim splitting' that are similar to claim preclusion, but that do not require a prior judgment."). Like the doctrine of claim preclusion, the rule against claim splitting fosters judicial economy, safeguards finality, and protects parties from vexatious or repetitive litigation. Id. When faced with claims split across duplicative lawsuits, a court can stay the later-filed action, dismiss it, or consolidate it with the earlier one. But whatever the remedy, the rationale remains the same: Plaintiffs "have no right to maintain two actions on the same subject in the same court, against the same defendant at the same time." Curtis v. Citibank, N.A., 226 F.3d 133, 138-39 (2d Cir. 2000).
+
+Here, Plaintiffs seek to advance claims on behalf ofJPMorgan as an entity, based on alleged wrongs done to the entity and ensuing harm accruing to the entity. Any recovery in this action will be in the name of the entity, not individual shareholders like Plaintiffs. Such is the nature of a derivative claim. But as this Court is well aware, the very entity whose claims and damages are at stake in this case—JPMorgan—has already sued Mr. Staley for claims premised on the same legal theories and arising out of the same events. See Doe v. JPMorgan, 1:22-cv-10019-/SR; USV/ v. JPMorgan, I:22-cv-10904-JSR.1e By any definition, therefore, the present derivative case is entirely duplicative of the already-existing lawsuit that JPMorgan has brought in its own name and right. That the derivative case is being directed by someone other than the bank itself does not change this analysis or the applicability of legal doctrines governing duplicative litigation. See Huck a rel. Sea Air Shuttle Corp. v. Dawson, 106 F.3d 45, 47 (3d Cir. 1997) (explaining that claim preclusion applies to dismiss subsequent derivative action based on similar claims); see also Barclay v. Lowe, 131 F. App'x 778, 779 (2d Cir. 2005) (unpublished) (affirming dismissal, on claim-splitting grounds, a second lawsuit with different defendants because such defendants were "in privily" with those in first suit). JPMorgan has already decided when and how it wants to sue Mr. Staley, and any additional claims it possesses could have been brought in that action. Those already-existing claims will be resolved in this Court in due course, and in the meantime, this Court should dismiss the duplicative claims against Mr. Staley in this action.
+
+<sup>18</sup> Although courts are typically limited to the four corners of a complaint when assessing a motion to dismiss, when analyzing claim preclusion or claims splitting, courts can consider documents incorporated by reference in the complaint or "not incorporated by reference" but "relie[d] heavily upon" in their "terms and effect." Coleman v. B.G. Sulzle, Inc., 402 F. Supp. 2d 403, 417 (N.D.N.Y. 2005) (citation omitted) (citing judicial actions not expressly incorporated in complaint when dismissing claims under claims splitting doctrine). And courts can judicially notice items appearing in the court records of prior litigation that are related to the case before it. Id.
+
+## CONCLUSION
+
+For the forgoing reasons, the Court should dismiss the claims against Mr. Staley.
+
+Date: July 6, 2023 Respectfully submitted,
+
+/s/ John McNichols
+
+John McNichols
+
+& CONNOLLY LLP
+
+680 Maine Avenue, S.W.
+
+Washington, DC 20024
+
+Tel: (202) 434-5252
+
+Fax: (202) 434-5029
+
+jincnichols®wc.com
+
+Counsel for Defendant James Edward Staley
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02823056/EFTA02823056.md b/marker2/court-pension-v-dimon/EFTA02823056/EFTA02823056.md
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@@ -0,0 +1,408 @@
+### UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+M Case No. 1:23-CV-03903 (JSR)
+
+DERIVATIVE ACTION
+
+### PLAINTIFFS' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANTS' MOTIONS TO DISMISS
+
+## TABLE OF CONTENTS
+
+| CITATION CONVENTIONS                                           | iii                                                             |
+|----------------------------------------------------------------|-----------------------------------------------------------------|
+| TABLE OF AUTHORITIES                                           | iv                                                              |
+| PRELIMINARY STATEMENT                                          | 1                                                               |
+| FACTUAL BACKGROUND                                             | 4                                                               |
+| I. COMPLIANCE WITH BSA/AML REGULATIONS IS MISSION-CRITICAL     | 4                                                               |
+| II. JPM FAILED TO EVEN ATTEMPT TO COMPLY WITH ITS BSA/AML      |                                                                 |
+| OBLIGATIONS WHILE EPSTEIN WAS A CLIENT                         | 5                                                               |
+| III. THE BOARD FAILED TO COMPLY WITH THE CONSENT               | ORDER AND                                                       |
+| DPA AFTER THE EPSTEIN RELATIONSHIP WAS TERMINATED              | 5                                                               |
+| IV. DEFENDANTS' BREACHES OF DUTY SIGNIFICANTLY HARMED JPM      | 7                                                               |
+| ARGUMENT                                                       | 7                                                               |
+| I. DEMAND IS EXCUSED BECAUSE A MAJORITY OF THE BOARD COULD     |                                                                 |
+| NOT IMPARTIALLY CONSIDER A DEMAND                              | 7                                                               |
+| A.                                                             | DIMON FACES A SUBSTANTIAL LIKELIHOOD OF LIABILITY FOR TURNING A |
+| EPSTEIN                                                        | 9                                                               |
+| B. =                                                           | CROWN, AND FLYNN FACE A SUBSTANTIAL LIKELIHOOD OF               |
+| LIABILITY FOR FAILING TO IMPLEMENT                             | BSA/AML BOARD LEVEL                                             |
+| REPORTING SYSTEMS                                              | II                                                              |
+| C. BAMMANN, =,                                                 | COMBS, CROWN, FLYNN, AND NEAL FACE A                            |
+| THE DPA AND CONSENT ORDERS                                     | 16                                                              |
+| D. NOVAKOVIC AND BAMMANN LACK INDEPENDENCE                     | 18                                                              |
+| E.                                                             | DEMAND IS EXCUSED AS TO THE CLAIM AGAINST STALEY AND THE UNJUST |
+| ENRICHMENT CLAIM                                               | 21                                                              |
+| II. THE RULE 12(B)(6) MOTIONS MUST BE DENIED BECAUSE THE       |                                                                 |
+| UNJUST ENRICHMENT                                              | 22                                                              |
+| A.                                                             | THE COMPLAINT STATES BREACH OF FIDUCIARY DUTY CLAIMS AGAINST    |
+| DIMON, =, COMBS, CROWN, FLYNN, AND KESSLER                     | 22                                                              |
+| B. THE COMPLAINT STATES AN UNJUST ENRICHMENT CLAIM AGAINST ALL |                                                                 |
+| DEFENDANTS                                                     | 23                                                              |
+| C. STALEY'S RULE 12(BX6) ARGUMENTS ARE MERITLESS               | 23                                                              |
+| I.                                                             | The Complaint States a Fiduciary Breach Claim Against Staley 23 |
+
+| 2.         | The Claims Against Staley Are Timely     | 24 |
+|------------|------------------------------------------|----|
+| 3.         | Staley's Claims-Splitting Argument Fails | 25 |
+| CONCLUSION |                                          | 25 |
+
+### CITATION CONVENTIONS
+
+| Verified Amended Stockholder Derivative Complaint (Doc. 17).                                                                                       | ¶ __.   |
+|----------------------------------------------------------------------------------------------------------------------------------------------------|---------|
+| Memorandum of Law in Support of Defendants' Motion to Dismiss (Doc. 25).                                                                           | DOB __. |
+| Defendant James E. Staley's Memorandum of Law in Support of Motion to Dismiss Complaint (Doc. 29).                                                 | SOB __. |
+| Exhibit to the Declaration of Christine M. Mackintosh in Support of Plaintiffs' Memorandum of Law in Opposition to Defendants' Motions to Dismiss. | Ex. __. |
+
+#### TABLE OF AUTHORITIES
+
+| Cases In re BGC P'rs, Inc. Derivative Litig.,                            | Page(s)       |
+|--------------------------------------------------------------------------|---------------|
+| 2019 WL 4745121 (DeI.Ch.) Braddock v. Zimmerman,                         | 7             |
+| 906 A.2d 776 (Del. 2006) CI Mason-Mahon v. Flint,                        | 9             |
+| 166 A.D.3d 754 (N.Y. App. 3d 2018) Calma v. Templeton,                   | 14            |
+| 114 A.3d 563 (Del. Ch.)                                                  | 23            |
+| 2021 WL 268779 (Del. Ch.) In re Clovis Oncology, Inc. Derivative Litig., | 22            |
+| 2019 WL 4850188 (Del. Ch.) Curtis v. Citibank, N.A.,                     | 12            |
+| 226 F.3d 133 (2d Cir. 2000) Delaware Cty. Emps. Ret. Fund v. M,          | 25            |
+| 124 A.3d 1017 (Del. 2015) In re Delta & Pine Land Co. S'holders Litig.,  | 18            |
+| 2000 WL 875421 (Del. Ch.) Epiphany Cmty. Nursery Sch. v. Levey,          | 21            |
+| 171 A.D.3d I (2019)                                                      | 25            |
+| 2016 WL 301245 (Del. Ch.) Helprin v. Harcourt, Inc.,                     | 3, 19, 20     |
+| 277 F. Supp. 2d 327 (S.D.N.Y. 2003) Howe v. Bank of N.Y. Mellon,         | 6             |
+| 783 F. Supp. 2d 466 (S.D.N.Y. 2011) Hughes v. Xiaoming Hu,               | 24            |
+| 2020 WL 1987029 (Del. Ch.)                                               | 2, II, 12, 16 |
+
+| Jane Doe 1 v. JPMorgan Chase Bank, N.A.,                                           |            |
+|------------------------------------------------------------------------------------|------------|
+| 2023 WL 3167633 (S.D.N.Y. May 1, 2023) Khan v. Portnoy,                            | passing    |
+| 2008 WL 5197164 (Del. Ch.) Largo Legacy Grp., LLC v. Charles,                      | 20         |
+| 2021 WL 2692426 (Del. Ch.) Marchand v. Barnhill,                                   | 24         |
+| 212 A.3d 805 (Del. 2019) Marino v. Grupo Mundial Tenedora S.A,                     | II, 14, 15 |
+| 810 F. Supp. 2d 601 (S.D.N.Y. 2011)                                                | 24         |
+| 2011 WL 2176479 (Del. Ch.) In re McDonald's Corp. S'holder Derivative Litig.,      | 9, 14      |
+| 289 A.3d 343 (Del. Ch.)                                                            | 9, 23      |
+| 2016 WL 4076369 (Del. Ch.)                                                         | 15         |
+| 854 A.2d 121 (Del. Ch.) Meyers v. Keeler,                                          | 11         |
+| 414 F. Supp. 935 (W.D. Okla. 1976) Oink                                            | 22         |
+| 2008 WL 5053448 (Del. Ch.)                                                         | 20         |
+| 2023 WL 3093500 (Del. Ch.) In re Oxford Health Plans, Inc.,                        | 14         |
+| 192 F.R.D. 111 (S.D.N.Y. 2000) In re Pfizer Inc. S'holder Der& Litig.,             | 14         |
+| 722 F. Supp. 2d 453 (S.D.N.Y. 2010) In re Pilgrim's Pride Corp. Derivative Litig., | passim     |
+| 2019 WL 1224556 (Del. Ch.) In re Ply Gem Indus., Inc. S'holders Litig.,            | 20         |
+| 2001 WL 1192206 (Del. Ch.)                                                         | 20         |
+
+| Ret. Fund v. Collis,                                                     |             |
+|--------------------------------------------------------------------------|-------------|
+| 2022 WL 17841215 (Del. Ch.) Ret. Fund v. Collis,                         | 13          |
+| 287 A.3d 1160 (Del. Ch.) Ret. Sys. v. Pyott,                             | 24          |
+| 46 A.3d 315 (Del. Ch.) Rich v. Chong,                                    | 8, 11       |
+| 66 A.3d 963 (Del. Ch.) Sandys v. Pincus,                                 | II          |
+| 152 A.3d 124 (Del. 2016) Silverzweig v. Unocal Corp.,                    | 18          |
+| A.2d 993 (Del. 1989) Staehr v. Hartford FiFin. Servs.Grp., Inc.,         | 22          |
+| 547 F.3d 406 (2d Cir. 2008)                                              | I I         |
+| 2020 WL 5028065 (Del Ch.) In re Tesla Motors, Inc. S'holder Litig.,      | 2, 9,21     |
+| 2018 WL 1560293 (Del. Ch.) In re Tyson Foods, Inc.,                      | 20          |
+| 919 A.2d 563 (Del. Ch.) Tri-State Pension Fund v. Zuckerberg,            | 24          |
+| 262 A.3d 1034 (Del. 2021) Westmoreland Cty. Emp. Ret. Sys. v. Parkinson, | 8           |
+| 727 F.3d 719 (7th Cir. 2013) Whittington v. Dragon Grp., LLC,            | 18          |
+| 991 A.2d 1 (Del. 2009) Other Authorities                                 | 24          |
+| Epstein's Accounts at JPMorgan; Jes Staley Says Dimon Did,               | WALL STREET |
+| JOURNAL (May 31, 2023)                                                   | 10          |
+| Rule 12(B)(6)                                                            | 22, 23      |
+
+Rule 23.1 9, 22
+
+Plaintiffs, derivatively on behalf of Nominal Defendant JPMorgan Chase & Co. ("JPM" or the "Company"), submit this memorandum of law in opposition to the motions to dismiss filed by Defendants and Nominal Defendant JPM (the "Motions").'
+
+## PRELIMINARY STATEMENT
+
+For fifteen years, JPM allowed a known felon convicted of soliciting a minor for prostitution and widely identified as having engaged in rampant sexual abuse to use the Company's facilities to further his criminal scheme. Epstein's abhorrent crimes received global attention and were well known throughout the organization, prompting many—including the Company's General Counsel and the CEO of the Company's Private Bank—to sound the alarm about the need to sever the relationship. But Epstein was also a very valued client with close ties to JPM secondin-command James E. Staley, and so the Company instead condoned Epstein's use of the Company to perpetuate his criminal activities, violating BSA and AML laws and regulations in the process.
+
+The threshold question presented by the Motions is whether demand on the Board to sue Defendants, including CEO Jamie Dimon, would have been futile. The answer to that question is "yes" where, as here, at least half of the board at the time the original complaint was filed (the "Demand Board") either face a substantial likelihood of liability or lack independence from someone who faces a substantial likelihood of liability. Here, seven members of the twelve-person Demand Board face a substantial likelihood of liability and an additional member lacks independence, excusing demand as to all counts.
+
+Dimon faces a substantial likelihood of liability because the Complaint's particularized allegations support a pleading-stage inference that Dimon knew JPM was violating the law by
+
+Capitalized terms used herein but not otherwise defined have the meanings ascribed to them in the Verified Amended Stockholder Derivative Complaint. Unless otherwise noted, all citations are omitted and all emphasis is added.
+
+facilitating Epstein's crimes, but took no action. Several members of JPM management who report directly to Dimon knew by no later than 2006 that Epstein was abusing underage girls and paying victims in cash. A 2008 document contemplated terminating JPM's relationship with Epstein "pending Dimon review." Staley testified that he spoke with Dimon about whether to maintain Epstein as a client in 2006 when he was arrested, in 2008 when he pleaded guilty, and several other times before 2012. These and other particularized allegations support a pleading-stage inference that Dimon was aware of "corporate misconduct"—the "proverbial `red flag'"—yet breached his duty of loyalty by "consciously disregard[ing his] duty to address that misconduct." Teamsters Local 443 Health Servs. & Ins. Plan v. Chou, 2020 WL 5028065, at \*17 (Del Ch.).
+
+The Board members at the time Epstein was a client (e.g., Crown, and Flynn), for their part, face a substantial likelihood of liability for failing to "establish[] [the Board's] own reasonable system of [BSA/AML compliance] monitoring and reporting, choosing instead to rely entirely on management." Hughes v. Xiaoming Hu, 2020 WL 1987029, at \*16 (Del. Ch.). "Caremark envisions some degree of board-level monitoring system, not blind deference to and complete dependence on management." Id. at \*4. Blind deference to and complete dependence on management is the only explanation for the Board's apparent failure to learn of Epstein's activities (and JPM's concomitant violations of law) while he was a client. Indeed, the Board's failure to establish its own system of BSA/AML compliance monitoring is confirmed by the 2013/2014 findings of the DOJ and OCC, who uncovered the same BSA/AML noncompliance that facilitated Epstein's crimes, levied criminal fines of \$2.1 billion, and entered into a deferred prosecution agreement ("DPA") with JPM in connection with the Madoff Ponzi scheme.
+
+Even after the Epstein relationship was terminated, and contrary to Defendants' claim that post-Epstein Board members did nothing wrong, the Board (e.g., Dimon, Bammann,
+
+Combs, Crown, Flynn, and Neal) continued breaching their duties. The Madoff DPA and Consent Orders entered into as a result of the Board's oversight failures expressly obligated management to report past misconduct (e.g., Epstein) to the Board. And—as Defendants appear to concede (DOB 7)—there is every reason to believe that management did so, including because JPM's General Counsel had previously sounded the alarm about Epstein and signed the DPA. Yet the Board—ignoring its obligation under the DPA and Consent Orders to ensure that information was provided to the DOJ-failed to require any retroactive SAR filings, failed to inform the DOJ or OCC of JPM's relationship with Epstein, and failed to hold any JPM executives accountable for facilitating Epstein's crimes. The Board's failure to comply with its heightened obligations makes the "inference of deliberate disregard by each and every member of the board...entirely reasonable." hi re Pfizer Inc. S'holder Deriv. Litig., 722 F. Supp. 2d 453, 462 (S.D.N.Y. 2010).
+
+Finally, the Complaint's particularized allegations raise a reasonable doubt as to Novakovic and Bammann's ability to impartially consider authorizing a lawsuit against Crown and Dimon, respectively. Novakovic is the CEO of a company in which the Crown family has substantial influence and "Delaware decisions have recognized that when a director is employed by" a company "where the interested party who would be adversely affected by pursuing litigation controls or has substantial influence over those entities, a reasonable doubt exists about that director's ability to impartially consider a litigation demand." hi re Ezcorp Inc Consulting Agreement Derivative Litig., 2016 WL 301245, at \*36 (Del. Ch.). Bammann faces similar independence concerns. She owes a significant portion of her professional success to Dimon, having worked under Dimon at both Bank One and JPM and having been appointed to the JPM Board in 2013—her sole employment since—when Dimon was Chairman and CEO. The requisite "nuanced and realistic approach" to assessing her independence leads to the inescapable
+
+conclusion that she could not impartially consider a demand to sue Dimon for misconduct that could end his career.
+
+Defendants' breaches of duty significantly harmed JPM. This action seeks to shift responsibility for that harm from JPM's stockholders to those responsible. None of Defendants' arguments support dismissal. The Motions should be denied.
+
+#### FACTUAL BACKGROUND
+
+Plaintiffs assume the Court's familiarity with the Complaint and the USV/ and Doe Actions and therefore only briefly summarize the Complaint's allegations below.
+
+# I. COMPLIANCE WITH BSA/AML REGULATIONS IS MISSION-CRITICAL
+
+JPM has acknowledged in SEC filings that it "is subject to extensive and comprehensive regulation under U.S. federal and state laws." ¶¶49-50. JPM has also disclosed that failure to comply with banking laws and regulations can subject JPM to "significant penalties and collateral consequences," including "greater exposure to litigation" and reputational damage. ¶¶50-51.
+
+Because JPM is susceptible to serving as a conduit for financial crimes, it is subject to a series of strict AML laws and regulations. ¶52. The BSA and Patriot Act require JPM to, inter alia, implement adequate risk-based AML policies and systems to detect and prevent money laundering and other uses of a bank's services and resources to facilitate criminal activity. ¶53. Such requirements include maintaining a due diligence program, filing SARs after detecting suspicious behavior, and filing currency transaction reports for transactions exceeding \$10,000/day. Id.
+
+Importantly, federal regulations require AML risk oversight at the board level. The FFIEC Manual provides, among other things, that "[t]he board of directors...is ultimately responsible for ensuring that the bank maintains an effective BSA/AML internal control structure, including suspicious activity monitoring and reporting." ¶¶54-55. According to the FFIEC Manual, customer due diligence policies and procedures are "critical" for "[a]voiding criminal exposure from persons
+
+who use...the bank's products and services for illicit purposes." ¶56.
+
+With respect to "high-risk customers," such as Epstein, the FFIEC Manual instructs that "(e]nhanced due diligence...is especially critical in understanding their anticipated transactions and implementing a suspicious activity monitoring system that reduces the bank's reputation, complaint, and transaction risks." ¶57. That suspicious activity monitoring system includes the filing of SARs, "the cornerstone of the BSA reporting system," if the bank knows, suspects, or has reason to suspect that a customer may be engaging in money laundering or other illegal activity. ¶58. Indeed, when a bank suspects suspicious activity, it must file a SAR within 30 days to the U.S. Department of Treasury's Financial Crimes Enforcement Network. ¶59. Upon the filing of a SAR, management should provide sufficient information in its SAR filings to the board—or an appropriate committee thereof—to fulfill its fiduciary duties. ¶60.
+
+### II. JPM FAILED TO EVEN ATTEMPT TO COMPLY WITH ITS BSA/AML OBLIGATIONS WHILE EPSTEIN WAS A CLIENT
+
+JPM onboarded Epstein in 1998. Id. By that time, he was well known for managing the fortunes of some of the world's richest and most powerful people. ¶¶8-9. And JPM was eager to curry favor with Epstein, as evidenced by its directive to Staley to "get to know him." ¶109.
+
+Company executives—who knew for at least seven years that Epstein was engaged in criminal activity—repeatedly expressed the need to sever the relationship, but JPM nevertheless permitted Epstein to use his corporate accounts to further his criminal activities with impunity. See, e.g., ¶¶113-22, 125-58. The Board, for its part, failed even to attempt to implement adequate AML risk oversight and, as a result, apparently remained ignorant to Epstein's crimes (or even the fact that Epstein was a client) until the relationship was terminated in 2013. Id.
+
+## III. THE BOARD FAILED TO COMPLY WITH THE CONSENT ORDER AND DPA AFTER THE EPSTEIN RELATIONSHIP WAS TERMINATED
+
+In January 2013, the 0CC found (and JPM consented to entry of an order fording) in
+
+connection with the Madoff Ponzi scheme that JPM (i) "failed to adopt and implement a compliance program that adequately covers the required BSA/AML program elements", (ii) "did not develop adequate due diligence on customers...a repeat problem, and failed to file all necessary SARs related to suspicious customer activity", and (iii) had numerous "critical deficiencies" in its BSA/AML compliance program, including "systemic deficiencies in its transaction monitoring systems, due diligence processes, risk management, and quality assurance programs." Ex. 1, Art. I.2 In January 2014, the Company agreed to pay \$2.1 billion in criminal fines and restitution (the largest BSA sanctions ever imposed) and entered into a DPA in which it admitted that it never filed a Madoff-related SAR over the course of several years despite suspicions about Madoffs Ponzi scheme. ¶¶170-71; DPA Ex. C ¶26.
+
+As part of prosecutors' willingness to forego criminally prosecuting JPM for its Madoff misconduct, JPM agreed to implement numerous Board-level undertakings to affirmatively identify and report all suspicious activities and transactions. Among other things, the Consent Orders required the Board to (i) implement an exhaustive review of all past SAR filings and ensure that any other potentially suspicious activity was identified and reported, (ii) review all transactions by non-bank financial institutions, which would have included JPM's use of Highbridge Capital's private jets to transport girls for Epstein's sex trafficking operation (¶¶114- 20), and (iii) oversee these reviews, with written findings "reported to the Board." See Ex. I, Arts. VIII, IX. The Consent Orders were unequivocal that JPM's obligations to remedy its BSA compliance failures fell to the Board—not management—and that the "Board shall ensure that the
+
+<sup>2</sup> The DPA is DOB Ex. I and the Consent Orders—attached hereto as Exs. 1-2—are referenced in the DPA and incorporated by reference into the Complaint. ¶¶170-71; Helprin v. Harcourt, Inc., 277 F. Supp. 2d 327, 331 (S.D.N.Y. 2003) (documents incorporated by reference where, as here, the Complaint makes "a clear, definite and substantial reference to the documents").
+
+Bank achieves and thereafter maintains compliance" with its obligations under the BSA and the Consent Orders. Ex. 1, Art. III(a)-(d).
+
+Moreover, the DPA imposed an affirmative obligation on JPM to inform the DOJ of "all criminal conduct by JPMorgan or any of its employees...as to which JPMorgan's Board, senior management, or U.S. legal compliance personnel are aware" and any "violations of the BSA that have come to the attention of JPMorgan's U.S. legal and compliance personnel." DPA ¶¶10, 20. That unquestionably should have included Staley's, Cutler's, Erdoes', Dimon's and other executives' knowledge of JPM's role in Epstein's sex trafficking, but no SAR was filed and nothing about JPM's relationship with Epstein was reported to the DOJ. ¶¶189-90. Reporting JPM's involvement may have been a breach of the DPA and subjected JPM to criminal prosecution—an extraordinarily severe consequence that perhaps explains, but does not excuse, the Board's failure to report anything Epstein-related. Indeed, rather than take these steps, JPM Managing Directors Nelson and continued to meet frequently with Epstein in New York and at his Santa Fe ranch until at least 2017. ¶157 n.95.
+
+# IV. DEFENDANTS' BREACHES OF DUTY SIGNIFICANTLY HARMED JPM
+
+As a result of Defendants' breaches, JPM has incurred significant costs, including the \$290 million settlement of the Doe Action, litigation costs incurred in the Doe and USV/ Actions, and reputational harm. The USV/ Action remains pending and likely will result in further harm.
+
+## ARGUMENT
+
+### I. DEMAND IS EXCUSED BECAUSE A MAJORITY OF THE BOARD COULD NOT IMPARTIALLY CONSIDER A DEMAND
+
+The demand futility test focuses on "whether the derivative plaintiff has shown some reason to doubt that the board will exercise its discretion impartially and in good faith." In re BGC P'rs, Inc. Derivative Litig., 2019 WL 4745121, at \*6 (Del.Ch.). A plaintiff can show mason to doubt a board's ability to exercise its discretion impartially and in good faith by adequately pleading that at least half of the directors (i) "face[] a substantial likelihood of liability on any of the claims that would be the subject of the litigation demand" or (ii) "lack[] independence from someone who...would face a substantial likelihood of liability of any of the claims that are the subject of the litigation demand." United Food & Commercial Workers Union & Participating Food Indus. Emps. Tri-State Pension Fund v. Zuckerberg, 262 A.3d 1034, 1059 (Del. 2021). Defendants suggest that demand is excused only if at least half of the board face a substantial likelihood of liability, DOB 11-12, but the Delaware courts aggregate directors who face a substantial likelihood of liability and those who lack independence. Zuckerberg, 262 A.3d at 1059.
+
+In evaluating a motion to dismiss for failure to make a demand, the Court "is required to accept the truth of all facts pleaded in the Complaint, and plaintiffs are entitled to all reasonable factual inferences that logically flow from the particularized facts alleged." Pfizer, 722 F. Supp. 2d at 458. The particularity requirement does not obligate a plaintiff "to demonstrate a reasonable probability of success on the claim," only to "make a threshold showing...that [its] claims have some merit." La. Mun. Emps.' Ret. Sys. v. Pyott, 46 A.3d 315, 351 (Del. Ch.).
+
+Demand is excused as to all counts because the Complaint adequately pleads that seven of twelve Demand Board directors face a substantial likelihood of liability and an additional director lacks independence:
+
+| DIRECTOR | SUBSTANTIAL LIKELIHOOD |
+|----------|------------------------|
+| Dimon    | X                      |
+| Bammann  | X X                    |
+| Combs    | X                      |
+| Crown3   | X                      |
+
+<sup>3</sup> Crown passed away in a tragic accident less than two months after the filing of the Original Complaint. Defendants concede (by silence), as they must, that the filing of the Amended
+
+| Flynn     | X |
+|-----------|---|
+| Neal      | X |
+| Novakovic | X |
+
+#### A. Dimon FACES A SUBSTANTIAL LIKELIHOOD OF LIABILITY FOR TURNING A BLIND EYE TO THE COMPANY'S LEGAL VIOLATIONS WITH RESPECT TO EPSTEIN
+
+Dimon had oversight duties in his capacity as an officer and director. In re McDonald's Corp. S'holder Derivative Litig., 289 A.3d 343, 369 (Del. Ch.). "An officer who receive[d] credible information indicating that the corporation is violating the law cannot turn a blind eye," id. at 370, because "Delaware law does not charter law breakers." Massey, 2011 WL 2176479, at •20. Rather, a fiduciary acts in bad faith where it "consciously disregard[s] its duty to address [corporate] misconduct." Chou, 2020 WL 5028065, at \*17.
+
+The following particularized allegations support a pleading-stage inference that Dimon knew that the Company was not complying with BSA/AML obligations with respect to Epstein but failed to cause the Company to sever its relationship with Epstein:
+
+- The CEO of JPM's Asset and Wealth Management business—who reported directly to Dimon—knew in 2006 that Epstein was abusing women and underage girls and paying victims in cash. 1131.
+- A July 2008 document contemplates a conversation in which the CEO of JPM's Private Bank would tell Staley that "we are uncomfortable with Epstein and do not want to go to Cutler [JPM's General Counsel] for approval." 1135.
+- A month later, a JPM employee wrote that she "would count Epstein's assets as a probable outflow for '08 (\$120mm or so?) as I can't imagine it will stay (pending [Iambi Dimon review)." 1136.
+- Between 2009 and 2011, Epstein helped schedule meetings for Dimon with
+
+Complaint did not alter the relevant board for assessing demand futility. See Braddock v. Zimmerman, 906 A.2d 776, 786 (Del. 2006) ("[W]hen an amended derivative complaint is filed, the existence of a new independent board of directors is relevant to a Rule 23.1 demand inquiry only as to derivative claims in the amended complaint that are not already validly in litigation."). All of the claims in the amended complaint were already validly in litigation.
+
+Netanyahu, Bill Gates, and Prince Andrew. 1123.
+
+- From 2006-2011, employees routinely raised concerns about Epstein. See, e.g., 9¶146-54.
+- In July 2011, the Company's General Counsel emailed Staley and Erdoes that Epstein should not be a client. 1155.
+
+Despite these and other glaring red flags, Epstein remained a client until 2013.
+
+Defendants effectively argue that the Complaint suffers from a lack of proof To wit, Defendants assert, inter alia, that (i) "the Complaint fails to allege with specificity that Mr. Dimon was aware of any red flags concerning Epstein's criminal activities," (ii) fails to allege that Dimon conducted the contemplated review of Epstein, (iii) "fails to plead what information was made available to Mr. Dimon [for the review] or what decision he even purportedly made," and (iv) "does not allege that Mr. Dimon was aware that Mr. Epstein was involved in the meeting. Mr. Staley purportedly attempted to schedule on Mr. Dimon's behalf1.]" DOB 21-22.
+
+But proof is not required at the pleading stage, and Defendants cannot deny Plaintiffs the reasonable inferences to which they are entitled. It is possible that (i) the CEO did not know that one of his largest clients was using the Company to facilitate sex trafficking for over a decade; (ii) several members of senior management knew of Epstein's crimes but unilaterally chose to conceal this knowledge from the CEO; (iii) the contemplated "Dimon review" of Epstein never happened or Dimon was provided insufficient information; (iv) Dimon never asked Staley how he secured the meetings with Netanyahu, Gates, and/or Prince Andrew (or the meetings did not occur), and (v) Staley perjured himself when he testified that he discussed Epstein with Dimon in 2006 when Epstein was arrested, in 2008 when Epstein pleaded guilty, and at various other times about whether to maintain Epstein as a client.°
+
+<sup>4</sup> Khadeeja Safdar, David Benoit, Jamie Dimon Says He Never Discussed Jeffrey Epstein's Accounts at JPMorgan; Jes Staley Says Dimon Did, WALL STREET JOURNAL (May 31, 2023), https://www.wsj.com/articles/jamie-dimon-says-he-never-discussed-jeffrey-epsteins-accounts-at-
+
+But it is far more likely—and, at a minimum, reasonably inferable—that Dimon knew who Epstein was and what he was doing, but prioritized profits over legal compliance (or otherwise chose to put his head in the sand). Metro Commc'n Corp. BVI v. Advanced Mobilecom Techs. Inc., 854 A.2d 121, 131 (Del. Ch.) ("[A] fiduciary may not choose to manage an entity in an illegal fashion."). At the motion to dismiss stage, the Court "must credit [the plaintiff-friendly] inference, even if [it] believe[s] it more likely that [Dimon] acted in good faith." Pyott, 46 A.3d at 356; Pfizer, 722 F. Supp. 2d at 458 (plaintiffs are entitled to "all reasonable inferences").
+
+### B. BURKE, CROWN, AND FLYNN FACE A SUBSTANTIAL LIKELIHOOD OF LIABILITY FOR FAILING TO IMPLEMENT BSA/AML BOARD LEVEL REPORTING SYSTEMS
+
+Directors are obligated to ensure management has implemented mechanisms and procedures sufficient to identify, monitor, and mitigate risks, and that there is a reporting system in place that enables the board to be kept informed as to how effectively management deals with those risks. See Hughes, 2020 WL 1987029, at •13-14; Rich v. Chong, 66 A.3d 963, 983-84 (Del. Ch.). "Caremark envisions some degree of board-level monitoring system, not blind deference to and complete dependence on management." Hughes, 2020 WL 1987029, at \*16. "The board is obligated to establish information and reporting systems that 'allow management and the board, each within its own scope, to reach informed judgments concerning both the corporation's c ompliance with law and its business performance." Id. (quoting Caremark, 608 A.2d at 959).
+
+Moreover, JPM is subject to extensive AML laws and regulations and JPM acknowledges in SEC filings that noncompliance can expose the Company "to significant penalties and collateral consequences." ¶¶49-60. "As Marchand makes clear, when a company operates in an environment
+
+jpmorgan-jes-staley-says-dimon-did-blIfOda5. See Staehr v. Hartford FiFin. Servs.Grp., Inc., 547 F.3d 406, 425 (2d Cir. 2008) (affirming the judicial notice of media reports and regulatory filings on a motion to dismiss).
+
+where externally imposed regulations govern its 'mission critical' operations, the board's oversight function must be more rigorously exercised." In re Clovis Oncology, Inc. Derivative Litig., 2019 WL 4850188, at \*12 (Del. Ch.). "Delaware courts are more inclined to find Caremark oversight liability at the board level when the company operates in the midst of obligations imposed upon it by positive law yet fails to implement compliance systems, or fails to monitor existing compliance systems, such that a violation of law, and resulting liability, occurs." Id.
+
+The Complaint's particularized allegations support a "pleading-stage inference that the board never established its own reasonable system of monitoring and reporting, choosing instead to rely entirely on management." Hughes, 2020 WL 1987029, at •16. Such an inference is supported by the fact that, as Defendants claim, Epstein's use of JPM to further his criminal scheme was never discussed at the Board level despite the national attention Epstein received and management's knowledge that the Company should not be doing business with Epstein, including:
+
+- When Epstein was onboarded in 1998, Know Your Customer due diligence would have unearthed the investigation into Epstein's alleged insider trading while at Bear Stearns and his proximity to the Tower Financial Ponzi scheme. ¶¶63, 112.
+- Epstein's 2006 arrest for soliciting a minor for prostitution received national attention and was discussed at the upper levels of JPM management. ¶¶126-31.
+- The Company was aware by 2006 that Epstein was abusing women and underage girls and was paying the victims in cash. ¶131.
+- Epstein's 2008 guilty plea for soliciting a minor for prostitution received national attention and caused some JPM employees, including the CEO of the Company's Private Bank, to advocate dropping him as a client. ¶¶133-35.
+- In 2010, memos from JPM compliance reference a federal investigation into Epstein. An employee in JPM's risk management division referred to "new allegations of an investigation related to child trafficking," and asked whether JPM was "still comfortable with this client who is now a registered sex offender." 11146-47.
+- In January 2011, JPM conducted a review of Epstein's accounts because a "few news stories during 2010 connect[ed] Jeffrey Epstein to human trafficking." 1149.
+- In March 2011, JPM's Global Corporate Security Division internally reported that
+
+"[n]umerous articles detail various law enforcement agencies investigating Jeffrey Epstein for allegedly participating, directly or indirectly, in child trafficking and molesting underage girls." ¶151.
+
+- In 2011, a senior JPM compliance official reviewed the Company's relationship with Epstein and warned that there was "Mots of smoke" and Mots of questions" surrounding Epstein's criminal behavior, including, inter a/ia, that (i) Epstein "is alleged to be involved in the human trafficking of young girls," (ii) AML Operations was "requesting that we exit this relationship," and (iii) JPM had "extended Epstein a loan in relation to [a] modeling agency" that was under DOJ investigation.1154.
+- In July 2011, Cutler emailed Staley and Mary Erdoes (CEO of JPM's Asset and Wealth Management business), among others, that Epstein "is not an honorable person in any way. He should not be a client" and later emailed Erdoes, "I would like to put it and him behind us. Not a person we should do business with, period."1155.
+- In August 2011, Ghislaine Maxwell applied to open a new account for a "personal recruitment consulting business," prompting the Company's AML director to ask: "What does she mean by personal recruitment?? Are you sure this will have nothing to do with Jeffrey? If you want to proceed, I suggest that we flag this as a High Risk Client." ¶156.
+
+One would have imagined that at least some of that information about one of the Company's largest clients would have made its way to the Board; Defendants insist that it did not.
+
+Although the Board apparently did not know, Epstein's use of the Company to further his well-publicized sex-trafficking operation—and the Company's concomitant breaches of its BSA/AML obligations—were happening in plain sight. In 2006, the JPM Rapid Response Team noted that Epstein routinely withdrew \$40,000 to \$80,000 in cash from his accounts several times each month—which, according to Dimon, would have been visible to JPM in real time (¶163) yet the Company failed to file SARs as required by federal law. ¶¶131, 159. At least 20 women trafficked and abused by Epstein were paid through JPM accounts between 2003 and 2013, many of whom had Eastern European surnames that were publicly and internally identified as Epstein recruiters and/or victims. 1164. And Epstein paid an additional \$1.5 million to well-known recruiters. 1165. Simply put, management "did not just see red flags; they were wrapped in them." Lebanon Cty. Emps.' Ret. Fund v. Collis, 2022 WL 17841215, at \*16 (Del. Ch.).
+
+But it was the Board that was "ultimately responsible for ensuring that the bank maintains an effective BSA/AML internal control structure, including suspicious activity monitoring and reporting." 955. The Board's utter failure to install oversight systems apparently blinded the Board to Epstein's use of JPM to further his criminal activity for years. C.f. Mason-Mahon v. Flint, 166 A.D.3d 754, 759 (N.Y. App. 3d 2018) ("In view of the illegal purpose, magnitude, and duration of the alleged wrongdoing...the allegations were such that the [wrongdoing] should have come to the attention of...the board of directors."). "When a plaintiff can plead an inference that a board has undertaken no efforts to make sure it is informed of a compliance issue intrinsically critical to the company's business operation, then that supports an inference that the board has not made the good faith effort that Caremark requires." Marchand v. Barnhill, 212 A.3d 805, 822 (Del. 2019); In re Oxford Health Plans, Inc., 192 F.R.D. III, 117 (S.D.N.Y. 2000) (applying Delaware law) ("[W]here liability is based upon a failure to supervise and monitor, and to keep adequate supervisory controls in place, demand futility is ordinarily found, especially where the failure involves a scheme of significant magnitude and duration which went undiscovered by the directors.").5
+
+JPM's admissions (and the government's findings) in connection with JPM's complicity in the Bernie Madoff scandal confirm that the Board failed to undertake required efforts to inform itself of BSA/AML compliance. See In re Massey Energy Co. Derivative and Class Action Litig., 2011 WL 2176479, at \*21 (Del. Ch.) (looking to company's record as a "recidivist" in assessing
+
+<sup>3</sup> See also Ontario Provincial Council of Carpenters' Pension Trust Fund v. Walton, 2023 WL 3093500, at \*33 (Del. Ch.) ("If the corporate trauma resulted from a central compliance area that fiduciaries acting in good faith would monitor, and if the corporate fiduciaries did not have a monitoring system that reflects a good faith effort to bring timely and actionable information to their attention, then the absence of such a system may support an inference that the corporate fiduciaries willfully blinded themselves to a known risk.").
+
+Caremark claim). The Madoff Ponzi scheme was conducted almost exclusively through JPM accounts and JPM settled two felony violations—and paid a \$1.7 billion criminal fine (the largest such sanction ever)—stemming from its failure to alert authorities to suspicious activity. ¶170. Defendants claim that Madoff is unrelated to Epstein, DOB 7, but the oversight deficiencies that enabled the Madoff Ponzi scheme were the same as those that enabled Epstein's crimes.
+
+Indeed, the OCC found that JPM "failed to adopt and implement a compliance program dial adequate/v covers the required BSA/AML program elements due to an inadequate system of infernal controls, and ineffective independence testing." Ex. 1, Art. 1. The OCC highlighted JPM's "previously identified systemic weaknesses in the adequacy of customer due diligence and the effectiveness of monitoring...constituting a deficiency in its BSA/AML compliance programs." Id. JPM—including the Board—was ordered to take a series of actions to comply with their BSA/AML reporting obligations, id., Arts. II-IV, IX-X, XII, confirming the Board's prior failure to make "the good faith effort that Caremark requires." Marchand, 212 A.3d at 822.
+
+Defendants' arguments leave them in a Caremark catch-22. They assert that JPM implemented robust systems to identify suspicious activity, but also that these "robust" systems left them unaware of Epstein's crimes (or even that he was a client). DOB 13-16. Defendants cannot have it both ways. Epstein was not just any client; he was an extremely valuable client that repeatedly met with JPM's most senior executives. And his transgressions were not isolated, secret, or insignificant; they were repeated, well known, and abhorrent. If JPM had implemented robust systems to identify suspicious activity, the Board necessarily would have known that one of JPM's largest clients was using the corporate machinery to further his sex-trat£cking operation. If it knew, the Board breached its duties by failing to promptly sever the relationship and report Epstein's misconduct. Melbourne Mun. Firefighters' Pension Tr. Fund on Behalf of Qualcomm,
+
+Inc. v. , 2016 WL 4076369, at •12 (Del. Ch.) (when board learns of illegality, it has an "immediate duty" to alter the company's "business practices"). If it did not know—as Defendants say—the Board breached its duties because Caremark does not permit "blind deference to and complete dependence on management." Hughes, 2020 WL 1987029, at \*16.
+
+Defendants otherwise engage in misdirection. They claim that the Complaint concedes that JPM had robust systems in place, DOB 16; SOB II, but ignore that the Complaint speaks to management reporting systems, not the board level reporting systems required by Delaware law!' Indeed, despite relying on the DPA, Defendants ignore that the DOJ's and OCC's findings confirm the lack of a board level reporting system. Defendants separately assert that the existence of Audit and Risk Committees forecloses a Caremark prong one claim, DOB 16, but in fact "[t]he mere existence of an audit committee and the hiring of an auditor does not provide universal protection against a Caremark claim." Hughes, 2020 WL 1987029, at \*14.
+
+JPM violated the law by allowing Epstein to use the Company to further his repugnant crimes for more than a decade. The particularized allegations support a pleading-stage inference that the Board willfully blinded itself to BSA/AML compliance, in breach of its duty of loyalty. The Board members who served while Epstein was a client—including M, Crown, and Flynn (and Dimon and Kessler)—thus face a substantial likelihood of liability.
+
+#### C. BAMMANN, BURKE, COMBS, CROWN, FLYNN, AND NEAL FACE A SUBSTANTIAL LIKELIHOOD OF LIABILITY FOR FAILING TO COMPLY WITH THE DPA AND CONSENT ORDERS
+
+In connection with entering into the DPA and Consent Orders, JPM agreed to (i) implement
+
+<sup>6</sup> Defendants' authority undercuts their claim. See SOB 11 (citing In re Gen. Motors Co. Derivative Litig., 2015 WL 3958724, at \*14 (Del. Ch.) (dismissing claim because company "had a system for reporting risk to the Board, but in [plaintiff]s view it should have been a better system").
+
+an exhaustive review of all past SARs filings and ensure that any other potentially suspicious activity was identified and reported, (ii) review all transactions by non-bank financial institutions, and (iii) oversee these reviews, with written findings "reported to the Board." See Ex. 1, Arts. VIII, IX. The Board was required to "ensure that the Bank achieves and thereafter maintains compliance" with its obligations under the Consent Orders. Ex. 1, Art. III(a)-(d); supra, Factual Background §111. And JPM was required to inform the DOJ of "all criminal conduct by JPMorgan or any of its employees...as to which JPMorgan's Board, senior management, or U.S. legal compliance personnel are aware" and "any violations of the BSA that have come to the attention of JPMorgan's...legal and compliance personnel." DPA ¶¶10, 20.
+
+It is reasonably inferable that JPM management—including Cutler, who repeatedly raised concerns about Epstein and who signed the DPA—complied with its obligations by identifying for the Board past suspicious activity concerning Epstein, particularly given that allegations concerning Epstein were increasingly "squarely in the public eye." ¶173; Pfizer, 722 F. Supp. 2d at 461 ("[T]hese agreements obligated Pfizer's chief Compliance Officer to report directly to the board...There is no reason to believe this reporting requirement was not fully complied with..."). It logically follows that it is reasonably inferable that the post-DPA Board members (e.g., Bammann, M t Combs, Crown, Flynn, and Neal) learned ofJPM's failure to timely file Epsteinrelated SARs and of Epstein's criminal conduct more generally.7 Yet, the Board failed to comply
+
+<sup>7</sup> As set forth herein, Bammann, M, Combs, Crown, Flynn, and Neal served on the Board during the term of the DPA (from 2014 to 2016) and the Consent Orders (OCC required committee disbanded in 2019). Hobson and Novakovic did not join the Board until 2018 and 2020, respectively. Although the Complaint credibly alleges that JPM continued to engage with Epstein until his death—including the frequent visits from JPM Managing Directors through 2017—and did not begin belatedly complying with its BSA obligations with respect to Epstein accounts until August 2019 (see, e.g., USVI (ECF No. 16) at ¶91), Plaintiffs are no longer pursuing the claims against them. Novakovic, however, lacks independence for reasons discussed below.
+
+with the DPA and Consent Orders by informing the DOJ of Epstein's crimes or JPM's BSA violations in connection therewith (or to take any other action against JPM executives until belatedly suing Staley after it became public that he sexually assaulted an Epstein victim).1189- 90. That was a breach of duty. See Westmoreland Cty. Emp. Ret. Sys. v. Parkinson, 727 F.3d 719, 726, 728 (7th Cir. 2013) (breach of duty to ignore "clear and specific guidance from [regulators]").
+
+Defendants contend that directors who joined the Board after the Epstein relationship was terminated cannot be held liable, DOB 5, but ignore the post-Epstein Board's failure to comply with the heightened duties imposed by the DPA and Consent Orders. The post-Epstein Board's failure to comply with those heightened duties makes the "inference of deliberate disregard by each and every member of the board...entirely reasonable." Pfizer, 722 F. Supp. 2d at 462.8
+
+# D. NOVAKOVIC AND BAMMANN LACK INDEPENDENCE
+
+A plaintiff can plead that a director is not independent by alleging facts from which the director's ability to act impartially against an interested party "can be doubted because that director may feel either subject to the interested party's dominion or beholden to that interested party." Delaware Cty. Emps. Ret. Fund v. , 124 A.3d 1017, 1024 n.25 (Del. 2015). At the pleading stage, a plaintiff satisfies this test by alleging that the director has relationships with an interested party that "might have a material effect on the parties' ability to act adversely toward each other." Sandys v. Pincus, 152 A.3d 124, 134 (Del. 2016). As Pincus observed, "[c]ausing a lawsuit to be brought against another person is no small matter, and is the sort of thing that might plausibly endanger a relationship." Id.
+
+<sup>8</sup> Although Defendants contend that JPM appropriately filed Epstein-related SARs (see DOB at 12, SOB at 19 n.17), that improper and counterfactual claim is contrary to the Complaint, the OCC's findings, the evidence in the Doe and USVI Actions, and the Court's class certification order—which notes SARs were filed in 2002, years before the Board's misconduct alleged here.
+
+Novakovic lacks independence from Crown. The Crown family inherited General Dynamics Corporation in 1959 and Crown served as a General Dynamics director from 1987 until his 2023 death. ¶¶12, 33. Novakovic joined General Dynamics in 2002 and became the Chairman and CEO of General Dynamics in 2013, a position she continues to enjoy at the pleasure of the Crown family. ¶¶36, 195. "Delaware decisions have recognized that when a director is employed by or receives compensation from other entities, and where the interested party who would be adversely affected by pursuing litigation controls or has substantial influence over those entities, a reasonable doubt exists about th(e] director's ability to impartially consider a litigation demand." Ezcorp, 2016 WL 301245, at \*36.
+
+Staley argues that the Complaint fails to allege that Crown or his family had substantial influence over General Dynamics, SOB 13-14, but the Complaint's particularized allegations support that inference. See e.g.,1112, 33, 195. The rest of the Defendants, for their part, bizarrely claim (in a footnote) that Crown's death somehow impacts the analysis. DOB 6 n.5. But even if it does, given that the Crown family continues to run General Dynamics, Novakovic would logically be as hesitant to authorize a lawsuit against Crown's estate—which could also unearth troubling ties between Crown and Epstein—as she would have been against Crown himself.
+
+In addition to facing a substantial likelihood of liability,' Bammann lacks independence of Dimon because she owes a significant portion of her professional success to Dimon. While Dimon was the CEO of Bank One, Bammann reached the status of Bank One's Executive Vice President and Chief Risk Management Officer from 2001 to 2004.1193. After JPM acquired Bank One—and when Dimon was JPM's President and Chief Operating Officer—Bammann served as
+
+<sup>9</sup> If the Court agrees that Bammann faces a substantial likelihood of liability, it need not reach independence.
+
+the Company's Deputy Head of Risk Management. Id. Bammann was then added to the Board in 2013—which has been her only employment since'°—when Dimon was Chairman and CEO. 1193. Considered holistically (as they must be), these allegations support a pleading-stage inference that Bammann may have felt a sense of owingness to Dimon that might have compromised her ability to impartially consider a demand. In re Ply Gem Indus., Inc. S 'holders Litig., 2001 WL 1192206, at •1 (Del. Ch.).
+
+Defendants' assertion that Bammann's independence cannot be compromised because her working relationship with Dimon ended some time ago, SOB 13, ignores that "past benefits conferred...may establish an obligation or debt (a sense of `owingness') upon which a reasonable doubt as to a director's loyalty to a corporation may be premised." Ply Gem, 2001 WL 1192206, at \*1; see also Off v. M, 2008 WL 5053448, at \*11 (Del. Ch.) ("[A] director `may feel beholden to someone for past acts."). Defendants also contend that "merely asserting close personal or business relationships is insufficient," DOB 17, but the Complaint in fact pleads particularized allegations supporting an inference that Bammann owes a significant portion of her professional success to Dimon. See, e.g., 1193. That is sufficient to compromise her independence.
+
+Defendants' arguments also ignore that Delaware takes a "nuanced and realistic approach to independence." /n re Pilgrim's Pride Corp. Derivative Litig., 2019 WL 1224556, •9 (Del. Ch.). Jamie Dimon is a giant in the industry who worked with Bammann. It blinks reality to suggest that Bammann—or, frankly, any other member of the Board—could impartially consider whether to authorize a lawsuit against Dimon for something that may destroy his reputation and end his career. Cf. In re Tesla Motors, Inc. S'holder Litig., 2018 WL 1560293, at •19 (Del. Ch.) (recognizing
+
+l° Cf. Khan v. Portnoy, 2008 WL 5197164, at •12 (Del. Ch.) (director compensation material where it exceeded compensation from other employment).
+
+relevance of Musk's "extraordinary influence within the Company generally" as relevant to independence analysis). The fact that the Board—including Bammann—is attempting to pin it all on Staley supports the inference that the Board is disposed toward protecting Dimon.
+
+#### E. DEMAND IS EXCUSED AS TO THE CLAIM AGAINST STALEY AND THE UNJUST ENRICHMENT CLAIM
+
+For the same reasons, a majority of the Board was incapable of considering a demand as to Count II against Staley and Count III for unjust enrichment. Staley claims that the analysis against him is different because demand futility is a "claim by claim determination," SOB 9-10, but Delaware courts have consistently held that a board's ability to consider litigation against officers is disabled where, as here, such litigation could implicate the board's own wrongdoing. See, e.g., Chou, 2020 WL 5028065, at \*26 (excusing demand where "the Director Defendants could not bring their business judgment to bear on a demand to prosecute [claims raised only against officers], because such litigation would implicate their own wrongdoing adequately pled in [claims raised against current directors]").
+
+Staley (and the rest of the Defendants) separately argue that demand cannot be futile because JPM has already sued Staley. SOB 8; DOB 10 n.10. JPM's belated and reactive decision to sue Staley is not the gleaming seal of impartiality that Defendants make it out to be, but rather a transparent attempt to deflect blame from Defendants' own longstanding facilitation of Epstein's horrific crimes onto a high-ranking executive no longer affiliated with JPM. Instead of proactively holding Staley accountable for his misconduct, JPM sued him because, to use Staley's words, it was finally "[c]onfronted with documented failures in its anti-money-laundering compliance" and "sought to change the narrative and deflect blame.""
+
+<sup>11</sup> Doe/USVI, Doc. 91 at I. Timing and Board conflicts distinguishes this case from those on which Defendants rely on. See, e.g., In re Delta & Pine Land Co. S'holders Litig., 2000 WL 875421, at \*6 (Del. Ch.) (Delta board sued ten days after planned merger collapsed, no similar board conflict);
+
+And that encapsulates the problem. In litigating the claim against Staley, the Company (controlled by the Board, including Defendants) is, incentivized to deflect blame. If evidence implicates Staley and additional Defendants, the Company could choose not to introduce it. If settling the claim against Staley at a non-maximizing price means that damaging information about other Defendants (or non-Defendant JPM employees, e.g., Erdoes) never comes to light, the Company may choose that route. Thus, even if the Court will not usurp the claim against Staley from the Company at this stage of its litigation, Plaintiffs should be permitted unfettered access to the evidence against Staley and a seat at the table of any settlement discussions (should they occur) to ensure that the Company's interests—not Defendants'—are being represented.
+
+#### II. THE RULE I2(B)(6) MOTIONS MUST BE DENIED BECAUSE THE COMPLAINT STATES CLAIMS FOR BREACH OF FIDUCIARY DUTY AND UNJUST ENRICHMENT
+
+#### A. THE COMPLAINT STATES BREACH OF FIDUCIARY Dun,CLAIMS AGAINST DIMON, =, COMBS, CROWN, FLYNN, AND KESSLER
+
+For the reasons discussed above, Defendants Dimon, M, Combs, Crown, and Flynn face a substantial likelihood of liability for breaching their fiduciary duties. "Because the pleading standard under Chancery Rule 23.1 is more demanding than the standard imposed by Chancery Rule 12(bX6), it follows that the motion to dismiss the claims against these same [] Board members for failure to state viable claims must also be denied." In re CBS Corp. S'holder Class Action & Derivative Litig., 2021 WL 268779, at \*4 (Del. Ch.). The Complaint also states a claim against Kessler, who was on the Board from 2004 — 2007, owed the same duties as the other directors, and
+
+Silverzweig v. Unocal Corp., 1989 WL 3231, at \*I, \*4 (Del. Ch.), affd sub nom., Silversweig v. Unocal Co A.2d 993 (Del. 1989) (Unocal board made proactive and unprompted decision to sue Sachs and others in connection with a tender offer; defendant directors faced no risk of liability); Meyers v. Keeler, 414 F. Supp. 935, 939 (W.D. Okla. 1976) (independent, proactive board action).
+
+engaged in the same misconduct. 1111 1-15, 87-92, 102-08,
+
+#### B. THE COMPLAINT STATES AN UNJUST ENRICHMENT CLAIM AGAINST ALL DEFENDANTS
+
+"At the pleading stage, an unjust enrichment claim that is entirely duplicative of a breach of fiduciary duty claim...is frequently treated 'in the same manner when resolving a motion to dismiss." Calma v. Templeton, 114 A.3d 563, 591 (Del. Ch. 2015) (citation omitted); DOB 24. Because the Complaint states claims for fiduciary breaches, the unjust enrichment claim survives.
+
+## C. STALEY'S RULE 12(s)(6) ARGUMENTS ARE MERITLESS
+
+Staley argues that Plaintiffs fail to state a claim and that Plaintiffs' claims are time-barred. SOB 15-20. This Court already rejected those arguments when Staley made them in response to JPM's third-party complaint against him. See Doe/USVI Doc. 126, at 18-23; Doc. 163. The Court should reject them again for the same reasons.
+
+## 1. The Complaint States a Fiduciary Breach Claim Against Staley
+
+One of Epstein's victims has now revealed that Staley assaulted at least one of Epstein's victims and "used aggressive force" in doing so while claiming Epstein had given Staley "permission to do what he wanted to her."I2 Staley nevertheless argues that he cannot be held liable because he had no obligations with respect to the Company's internal controls. Put differently, Staley argues that even if he knew that JPM was breaking the law (and even if he participated in Epstein's crimes), he had no obligation to tell the Board and no obligation to stop it from happening. The Court of Chancery has expressly rejected that argument: "An officer who receives credible information indicating that the corporation is violating the law cannot turn a blind eye and dismiss the issue as 'not in my area." McDonald's, 289 A.3d at 370.
+
+<sup>12</sup> Jane Doe I v. JPMorgan Chase Bank, N.A., 2023 WL 3167633, at •3 (S.D.N.Y. May 1, 2023).
+
+Moreover, even assuming counterfactually that the Plaintiffs were required to plead that Staley had some specific oversight duty with respect to Epstein, Plaintiffs easily meet that standard. When Epstein was retained as a high-value client, Staley (as head of JPM's private banking division) was specifically tasked with "get[ing] to know" Epstein. ¶15. And when Staley became the CEO of JPM's Asset Management Division, an internal risk function memorandum noted that employees would report to Staley about the risk Epstein presented as a client. ¶18. Indeed, JPM has alleged that "Staley's act of disloyalty...occurred in his primary area of responsibility."13 Staley cannot escape liability for his significant involvement in furthering Epstein's crimes, e.g. ¶¶135-44, by falsely claiming that Epstein was outside of his purview.
+
+#### 2. The Claims Against Staley Are Timely
+
+The Court correctly rejected Staley's statute of limitations arguments in the related Doe/USVI Actions and should do so again here. Staley incorrectly relies on New York law. SOB 18. Delaware law,14 which recognizes the concept of equitable tolling,15 applies. Such tolling is available where "a plaintiff has reasonably relied upon the competence and good faith of a fiduciary." In re Tyson Foods, Inc., 919 A.2d 563, 585 (Del. Ch.). Claims are tolled until "the plaintiff is aware of the injury, or should have discovered it in the exercise of reasonable diligence." Lebanon Cnty. Emps.' Ret. Fund v. Collis, 287 A.3d 1160, 1212 (Del. Ch.).16
+
+<sup>13</sup> Doe/USVI, Doc. 59 at ¶76 (cited at SOB 21 n.18).
+
+<sup>&</sup>quot; in diversity cases brought in New York federal court, New York's conflict of law rules govern, Marino v. Grupo Mundial Tenedora S.A, 810 F. Supp. 2d 601, 606 (S.D.N.Y. 2011), New York law applies the internal affairs doctrine, id., which in turn applies the laws of the state of incorporation. Howe v. Bank of N.Y. Mellon, 783 F. Supp. 2d 466, 475 (S.D.N.Y. 2011).
+
+<sup>13</sup> Equitable claims under Delaware law are governed by the doctrine of laches, the equitable (and more flexible) analog of a statute of limitations defense. See Whittington v. Dragon Gip., LLC, 991 A.2d 1, 8 (Del. 2009). The relevant laches period here is three years. See Largo Legacy Grp., LLC v. Charles, 2021 WL 2692426, at \*9 (Del. Ch.).
+
+<sup>16</sup> Similarly, under New York law, "[w]here [the record] does not conclusively demonstrate that a
+
+The claims against Staley were equitably tolled until the Doe and USV/ Actions were filed in late 2022 because Plaintiffs previously had no way of knowing of Staley's knowledge of (much less participation in) Epstein's crimes. Indeed, if the Company could not be expected to discover the claims against Staley before the Doe and USV! Actions were filed, Plaintiffs—stockholders with no access to, e.g., communications involving Staley and Epstein—certainly could not have been. And, by any measure, Plaintiffs acted with sufficient alacrity in filing suit against Staley, thereby defeating any claim of unreasonable delay.
+
+# 3. Staley's Claims-Splitting Argument Fails
+
+Application of the claim-splitting doctrine is discretionary. Curtis v. Citibank, N.A., 226 F.3d 133, 138 (2d Cir. 2000). The Court should exercise its discretion to reject Staley's claimsplitting argument for the same reason that Staley's demand futility argument should be rejected. Staley contends that because the Company is already pursuing claims against him, Plaintiffs should not be permitted to do so. SOB 20-21. But Plaintiffs already explained why the Company cannot be trusted to maximize the value of the claims against Staley. See supra, Argument § I.E. Any benefits of claim-splitting therefore are outweighed by the potential harm to the Company.
+
+## CONCLUSION
+
+For the foregoing reasons, the Motions should be denied. If the Court is inclined to grant the Motions, Plaintiffs should be permitted to amend the Complaint, including to incorporate the discovery produced after it was filed.
+
+plaintiff had knowledge of facts from which the alleged fraud might be reasonably inferred, the cause of action should not be disposed of summarily on statute of limitations grounds." Epiphany Cmty. Nursery Sch. v. Levey, 171 A.D.3d I, 7 (2019).
+
+Dated: July 20, 2023
+
+BERNSTEIN LITOWITZ BERGER & GROSSMAN LLP
+
+Daniel Meyer Andrew Blumberg 500 Delaware Avenue, Suite 901 Wilmington, DE 19801 (302) 364-3600
+
+Respectfully submitted,
+
+BERNSTEIN LITOWITZ BERGER & GROSSMAN LLP
+
+/s/ Michael D. Blatchley
+
+Jeroen van Kwawegen Michael D. Blatchley 1251 Avenue of the Americas New York, NY 10020 (212) 554-1400
+
+Counsel for Plaintiff City of Miami General Employees & Sanitation Employees Retirement Trust
+
+GRANT & EISENHOFER P.A.
+
+Is/ Christine M. Mackintosh
+
+Rebecca A. Musarra J. Orrico Vivek Upadhya 485 Lexington Avenue, 29th Floor New York, NY 10017 (646) 722-8500
+
+Michael J. Barry (admitted pro hac vice) Christine M. Mackintosh (admitted pro hac vice) 123 Justison Street Wilmington, DE 19801 (302) 622-7000
+
+Counsel for Plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02823090/EFTA02823090.md b/marker2/court-pension-v-dimon/EFTA02823090/EFTA02823090.md
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@@ -0,0 +1,451 @@
+# EXHIBIT 1
+
+#2013-002
+
+AA-EC-134m
+
+#### UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY COMPTROLLER OF THE CURRENCY
+
+)
+
+In the Matter of: )
+
+)
+
+JPMorgan Chase Bank, N.A. ) Columbus, )
+
+)
+
+JPMorgan Bank and Trust Company, N.A., San ) Francisco, CA )
+
+)
+
+Chase Bank USA, N.A., ) Newark, DE )
+
+> ) )
+
+# CONSENT ORDER
+
+WHEREAS, the Comptroller of the Currency of the United States of America ("Comptroller"), through his national bank examiners and other staff of the Office of the Comptroller of the Currency ("OCC"), has conducted examinations of JPMorgan Chase Bank, N.A., Columbus, Ohio; JPMorgan Bank and Trust Company, N.A., San Francisco, California; and Chase Bank USA, N.A., Newark, Delaware (collectively referred to as "Bank"). The OCC has identified deficiencies in the Bank's overall program for Bank Secrecy Act/Anti-Money Laundering ("BSA/AML") compliance and has informed the Bank of the findings resulting from the examinations.
+
+WHEREAS, the Bank, by and through its duly elected and acting Boards of Directors (collectively referred to as "Board"), has executed a "Stipulation and Consent to the Issuance of a Consent Order," dated January 14 2013, that is accepted by the Comptroller ("Stipulation"). By this Stipulation and Consent, which is incorporated by reference, the Bank has consented to the issuance of this Consent Cease and Desist Order ("Order") by the Comptroller, pursuant to 12 U.S.C. § 1818(6). The Bank has begun corrective action, and has committed to taking all necessary and appropriate steps to remedy the deficiencies identified by the OCC, and to enhance the Bank's BSA/AML compliance program.
+
+# ARTICLE I
+
+# COMPTROLLER'S FINDINGS
+
+The Comptroller finds, and the Bank neither admits nor denies, the following:
+
+(1) The OCC's examination findings establish that the Bank has deficiencies in its BSA/AML compliance program. These deficiencies have resulted in the failure to correct a previously reported problem and a BSA/AML compliance program violation under 12 U.S.C. § 1818(s) and its implementing regulation, 12 C.F.R. § 21.21 (BSA Compliance Program). In addition, the Bank has violated 12 C.F.R. § 21.11 (Suspicious Activity Report Filings).
+
+(2) The Bank has failed to adopt and implement a compliance program that adequately covers the required BSA/AML program elements due to an inadequate system of internal controls, and ineffective independent testing. The Bank did not develop adequate due diligence on customers, particularly in the Commercial and Business Banking Unit, a repeat problem, and failed to file all necessary Suspicious Activity Reports ("SARs") related to suspicious customer activity.
+
+(3) The Bank failed to correct previously identified systemic weaknesses in the adequacy of customer due diligence and the effectiveness of monitoring in light of the customers' cash activity and business type, constituting a deficiency in its BSA/AML compliance program and resulting in a violation of 12 U.S.C. § 1818(s)(3)(B).
+
+(4) Some of the critical deficiencies in the elements of the Bank's BSA/AML compliance program, resulting in a violation of 12 U.S.C. § 1818(s)(3)(A) and 12 C.F.R. § 21.21, include the following:
+
+- (a) The Bank has an inadequate system of internal controls and independent testing.
+- (b) The Bank has less than satisfactory risk assessment processes that do not provide an adequate foundation for management's efforts to identify, manage, and control risk.
+- (c) The Bank has systemic deficiencies in its transaction monitoring systems, due diligence processes, risk management, and quality assurance programs.
+- (d) The Bank does not have enterprise-wide policies and procedures to ensure that foreign branch suspicious activity involving customers of other bank branches is effectively communicated to other affected branch locations and applicable AML operations staff. The Bank also does not have enterprise-wide policies and procedures to ensure that on a risk basis, customer transactions at foreign branch locations can be assessed, aggregated, and monitored.
+
+(e) The Bank has significant shortcomings in SAR decision-making protocols and an ineffective method for ensuring that referrals and alerts are properly documented, tracked, and resolved.
+
+(5) The Bank failed to identify significant volumes of suspicious activity and file the required SARs concerning suspicious customer activities, in violation of 12 C.F.R. § 21.11. In some of these cases, the Bank self-identified the issues and is engaged in remediation.
+
+(6) The Bank's internal controls, including filtering processes and independent testing, with respect to Office of Foreign Asset Control ("OFAC") compliance are inadequate.
+
+NOW, THEREFORE, IT IS ORDERED that:
+
+# ARTICLE II
+
+#### COMPLIANCE COMMITTEE
+
+(1) The Board shall appoint and maintain a Compliance Committee of at least three (3) directors, of which a majority may not be employees or officers of the Bank or any of its subsidiaries or affiliates. The names of the initial members of the Compliance Committee shall be submitted in writing to the Examiner-in-Charge for a written determination of no supervisory objection. In the event of a change of the membership, the name of any new member shall be submitted in writing to the Examiner-in-Charge at the Bank ("Examiner-in-Charge") for a written determination of no supervisory objection. The Compliance Committee shall be responsible for coordinating and
+
+monitoring the Bank's adherence to the provisions of this Order. The Compliance Committee shall meet at least monthly and maintain minutes of its meetings.
+
+(2) Within ninety (90) days of this Order, and quarterly thereafter, the Compliance Committee shall submit a written progress report to the Board setting forth in detail the actions taken to comply with each Article of this Order, and the results and status of those actions. including improvements to the BSA/AML Program.
+
+(3) The Board shall forward a copy of the Compliance Committee's report, with any additional comments by the Board, to the Deputy Comptroller for Large Bank Supervision ("Deputy Comptroller") and the Examiner-in-Charge within ten (10) days of receiving such report.
+
+# ARTICLE III
+
+# COMPREHENSIVE BSA/AML ACTION PLAN
+
+(I) Within sixty (60) days of this Order, the Bank shall submit to the Deputy Comptroller and the Examiner-in-Charge a plan containing a complete description of the actions that are necessary and appropriate to achieve full compliance with Articles IV through XI of this Order ("BSA/AML Action Plan"). The Bank shall implement the BSA/AML Action Plan upon the Deputy Comptroller's issuance of a written determination of no supervisory objection. In the event the Deputy Comptroller requires the Bank to revise the plan, the Bank shall promptly make and the Board shall approve necessary and appropriate revisions and resubmit the BSA/AML Action Plan to the Deputy Comptroller and Examiner-in-Charge for review and determination of no supervisory objection. Following implementation, the Bank shall not take any action that will cause a significant deviation from, or material change to, the BSA/AML Action Plan unless and until the Bank has received a prior written determination of no supervisory objection from the Deputy Comptroller.
+
+- (a) The Board shall ensure that the Bank achieves and thereafter maintains compliance with this Order, including, without limitation, successful implementation of the BSA/AML Action Plan. The Board shall further ensure that, upon implementation of the BSA/AML Action Plan, the Bank achieves and maintains an effective BSA/AML compliance program, in accordance with the BSA and its implementing regulations. In each instance in this Order in which the Board is required to ensure adherence to or undertake to perform certain obligations of the Bank, it is intended to mean that the Board shall: Authorize and adopt such actions on behalf of the Bank as may be necessary for the Bank to perform its obligations and undertakings.
+- (b) Require the timely reporting by Bank management of such actions directed by the Board to be taken under this Order;
+- (c) Require corrective action be taken in a timely manner for any noncompliance with such actions; and
+- (d) Follow-up on any non-compliance with such actions in a timely and appropriate manner.
+- (2) The BSA/AML Action Plan must specify timelines for completion of each of the requirements of Articles IV through XI of this Order. The timelines in the
+
+BSA/AML Action Plan shall be consistent with any deadlines set forth in these Articles, unless modified by written agreement with the Deputy Comptroller or the Examiner-in-Charge.
+
+(3) Upon request by the Deputy Comptroller or the Examiner-in-Charge, the Bank shall modify the BSA/AML Action Plan to address any Matters Requiring Attention concerning BSA/AML matters, or citations of violations of law concerning BSA/AML matters, which the OCC may issue to the Bank following the effective date of this Order.
+
+(4) The Bank shall ensure that it has sufficient processes, personnel, and control systems to implement and adhere to this Order. The BSA/AML Action Plan must specify in detail budget outlays and staffing, including aggregated staff compensation information in a format acceptable to the Examiner-in-Charge, that are necessary to achieve and maintain full compliance with Articles IV through XI of this Order.
+
+(5) Any independent consultant or auditor engaged by the Bank or the Board to assist in the assessment of the BSA/AML Action Plan or other compliance with this Order must have demonstrated and specialized experience with the BSA/AML matters that are the subject of the engagement, and must not be subject to any conflict of interest affecting the consultant's or auditor's independence.
+
+(6) Within ten (10) days of this Order, the Bank shall designate an officer to be responsible for coordinating and submitting to the OCC the written plans, reports, and other documents required to be submitted under the terms and conditions of this Order.
+
+#### ARTICLE IV
+
+#### MANAGEMENT AND ACCOUNTABILITY
+
+(I) The Bank shall ensure there are clear lines of authority and responsibility for BSA/AML and OFAC compliance with respect to lines of business and corporate functions, and that competent and independent compliance management is in place on a full-time basis.
+
+(2) The Bank shall ensure that compliance staff has the appropriate level of authority to implement the BSA/AML Compliance Program and, as needed, question account relationships and business plans. Compliance staff shall maintain independence from the business line. The Bank shall follow any applicable guidance addressing independence issued by the OCC or the FFIEC.
+
+(3) The Bank shall ensure that senior management and line of business management are accountable for effectively implementing bank policies and procedures, and fulfilling BSA/AML/OFAC obligations. The Bank shall incorporate BSA/AML and OFAC compliance into the performance evaluation process for senior and line of business management. Additionally, written Bank policies and procedures shall clearly outline the BSA/AML/OFAC responsibilities of senior management and relevant business line employees, including, but not limited to, relationship managers, business banking, commercial banking, correspondent banking and private banking personnel, and legal and business development staff.
+
+(4) The Bank shall develop appropriate objectives and means to measure the effectiveness of compliance management officers and compliance management personnel within each line of business and for those with responsibilities across lines of business.
+
+(5) The Board shall not permit any other party, including but not limited to the Bank's holding company, to perform any act on behalf of the Bank which is the subject of this Order, unless the Bank requires that party to perform such act in the manner and under safeguards and controls as least as stringent as required by the Bank under the terms of this Order as implemented by the Bank.
+
+# ARTICLE V
+
+# BSA/AML AND OFAC COMPLIANCE PROGRAM EVALUATION AND RISK ASSESSMENT
+
+(1) Within 60 days of this Order, the Bank shall provide an action plan for the completion of an evaluation of the Bank's BSA/AML and OFAC Compliance Programs to the Examiner-in-Charge for no supervisory objection. If the Examiner-in-Charge recommends changes to the evaluation, the Bank shall incorporate those changes or suggest alternatives that are acceptable to the Examiner-in-Charge.
+
+(2) The evaluation required pursuant to Paragraph (1) of this Article shall be completed and submitted to the Examiner-in-Charge within 90 days following the nonobjection of the Examiner-in-Charge to the action plan referred to in Article V(1). This evaluation shall include assessments of the BSA/AML and OFAC Compliance Programs' organizational structure, enterprise-wide effectiveness, competency of management, accountability, staffing requirements, internal controls, customer due diligence processes, risk assessment processes, suspicious activity monitoring systems, audit/independent testing, and training. The evaluation shall include recommendations for enhancements needed to achieve remediation of any deficiencies identified in the evaluation.
+
+(3) This evaluation shall also include a comprehensive assessment of the Bank's BSA/AML risk, including detailed quantification of risk to accurately assess the level of risk and the adequacy of controls. The comprehensive assessment shall include:
+
+- (a) An assessment of the AML risk associated with each line of business, and an enterprise-wide assessment of AML risk. This evaluation shall include, but not be limited to, an assessment of the risk associated with correspondent banking, pre-paid cards and mobile banking, cash-intensive businesses, remote deposit capture, business, commercial, and private banking, and other higher risk products, services, customers, or geographies. The purpose of the enterprise-wide assessment is to identify systemic AML risk that may not be apparent in a risk assessment focused on line of business or assessment units;
+- (b) Evaluation of the Bank's current methodology for identifying and quantifying the level of BSA/AML risk associated with categories of customers and for specific customers. The methodology should ensure that the relationships are reviewed holistically, across lines of business, taking into consideration the risk within the Bank. This evaluation shall result in the development of a comprehensive approach to quantifying BSA/AML risk for new and existing customers. The quantification of risk shall encompass a customer's entire relationship with the Bank, include the purpose of the account, actual or anticipated activity in the account (e.g.,
+
+type, volume, and value (number and dollar) of transaction activity engaged in), nature of the customer's business or occupation, customer location (e.g., customers' geographic location, where they transact business, and have significant operations), types of products and services used by the customer, material changes in the customer's relationship with the Bank, as well as other factors discussed within the FFIEC BSA/AML Examination Manual;
+
+- (c) The identification of specific lines of business, geographies, products or processes where controls are not commensurate with the level of AML risk exposure;
+- (d) The risk assessment shall be refreshed periodically, the timeframe for which shall not exceed twelve months, or whenever there is a significant change in AML risk within the Bank or line of business. The AML risk assessments shall also be independently reviewed by the Bank's internal audit function for the adequacy of identification of risk; control plan to manage identified risks; gap analyses where controls are not sufficient; and action plans to address gaps; and
+- (e) The aggregation of the Bank's enterprise-wide AML risk shall be logical and clearly supported in the work papers. The work papers and supporting documentation shall be readily accessible for OCC review.
+
+(4) OFAC risk shall be included within the BSA/AML risk assessment, using the same criteria as described above in paragraphs 2(a) through (e) of this Article.
+
+#### ARTICLE VI
+
+#### CUSTOMER DUE DILIGENCE
+
+(1) Within 90 days of this Order, the Bank shall ensure that appropriate customer due diligence policies, procedures, and processes are developed. These controls shall be implemented and applied on a Bank-wide basis. Minimum corporate standards shall provide general guidance, and individual lines of business and AML compliance management shall develop standards based on their client base, products, services, geographic risk, and other AML risk factors. Customer due diligence shall be commensurate with the customer's risk profile, and sufficient for the bank to develop an understanding of normal and expected activity for the customer's occupation or business operations. The customer due diligence process shall include the following items:
+
+- (a) Information regarding the client's/customer's relationships with the Bank, all lines of business within the Bank, and all Bank subsidiaries or affiliates (that are subject to management control by the Banks' holding company). This includes accounts within other lines of business, regions, and countries (as permitted by jurisdiction). The relationship includes its owners, principals, signers, subsidiaries, affiliates, and parties with the ability to manage or control the account or client;
+
+- (b) An electronic due diligence database, which includes information specified in subparagraph (a) above, that is readily accessible to the relationship manager or other parties responsible for the customer relationship, AML compliance personnel, suspicious activity monitoring alert analysts and investigators, and quality control and assurance personnel;
+- (c) Customer due diligence shall be periodically updated to reflect changes in the customer's behavior, activity profile, derogatory information, periodic reviews of the customer relationship, or other factors that impact the AML risk for the client and shall include any remediation required by the standards required by the Article. The frequency of the periodic update of due diligence shall be based on risk with the update performed at least annually for highrisk relationships, triennially for low-risk business relationships, and as appropriate for low-risk individuals. The periodic updates shall be documented, and subject to quality assurance processes;
+- (d) The client relationship AML risk shall be detailed in the customer due diligence record, along with the supporting factors, including transaction activity, geographies involved, and suspicious activity monitoring alert and filing history, among others;
+- (e) Specialized or enhanced due diligence for higher risk clients and/or products and services shall be implemented enterprise-wide. These due diligence standards shall comply with the FFIEC
+
+BSA/AML Examination Manual, the Interagency Guidance on Beneficial Ownership Information (OCC 2010-11), as well as industry standards; and
+
+(0 Management processes to periodically review, based on the relationship risk, the type, volume, and value of customer activities in relation to normal and expected levels. The purpose of these reviews shall be to determine if the customer's activity is reasonable, that customer due diligence is current and complete, and the customer risk rating is accurate. These reviews shall be documented and quality assurance processes must ensure the reviews are comprehensive and accurate. Standards and processes shall be established for elevating reviews for additional management consideration regarding increased monitoring, additional due diligence, or account closure/
+
+- (2) The Bank shall submit its policies and procedures for customer due diligence to the Examiner-in-Charge for prior no supervisory objection. If the Examinerin-Charge recommends changes to the policies or procedures, the Bank shall incorporate those changes or suggest alternatives that are acceptable to the Examiner-in-Charge.
+
+# ARTICLE VII
+
+# SUSPICIOUS ACTIVITY IDENTIFICATION AND REPORTING
+
+- (I) Within 60 days of this Order, the Bank shall develop and thereafter shall maintain a written program of policies and procedures to ensure, pursuant to 12 C.F.R.
+
+§ 21.11, the timely and appropriate review and disposition of suspicious activity alerts, and the timely filing of Suspicious Activity Reports ("SARs").
+
+(2) Within 30 days of this Order, the Bank shall retain or continue an existing or newly revised relationship with one or more independent consultants acceptable to the Examiner-in-Charge to evaluate its suspicious activity identification processes to ensure they are effective and provide comprehensive coverage to the Bank. This evaluation shall include an assessment of the capabilities of any surveillance and transaction monitoring systems used; the scope of coverage provided by the systems; and the management of those systems. Upon completion, the Bank shall submit this evaluation to the Examiner-in-Charge for no supervisory objection. The evaluation shall address, but not be limited to, the following issue:
+
+- (a) An assessment of the functionality of automated transaction monitoring systems used to determine if the systems are sufficiently robust to provide for the timely identification of potentially suspicious activity. A comprehensive listing of weaknesses or deficiencies in the system and the risks presented by these deficiencies shall be highlighted for management consideration:
+
+Management's implementation of each surveillance and transaction (3) monitoring system shall ensure the following:
+
+- (a) The integrity of data feeding the transaction monitoring systems;
+- (b) The system has been sufficiently tailored to the Bank's risk profile and operations;
+
+- (c) The system's functionality is being utilized to appropriately address risk, including the ability to aggregate data across platforms, lines of business, and relationships; and
+- (d) The business logic units, parameters, rules, or other factors selected for automated monitoring are appropriate and effective in identifying client activity that is unreasonable or abnormal given the nature of the client's occupation or business and expected activity. In addition, there shall be:
+  - (i) Sufficient management information and metrics to manage and adjust the system, as necessary; and
+  - (ii) Statistically valid processes to validate and optimize monitoring system settings and thresholds, and to measure the effectiveness of the automated system and individual scenarios, where appropriate.
+
+- (4) Management implementation of the alert investigation processes shall
+
+ensure the following:
+
+- (a) The adequacy of staffing to investigate and clear alerts;
+- (b) The quality and completeness of information available to analysts working transaction monitoring alerts and conducting investigations;
+- (c) The standards for dispositioning different types of alerts are reasonable, communicated in writing to relevant staff, and are adhered to by the alert investigators;
+
+- (d) Adequate documentation is maintained to support the disposition of alerts;
+- (e) The availability and adequacy of information to investigate potentially suspicious activity, including, if applicable, information from multiple lines of business a customer transacts with or information from bank subsidiaries or affiliates (that are subject to management control by the Banks' holding company), and information concerning foreign suspicious activity reports involving United States customers; (0 Standards that ensure accounts with high volumes of alerts are identified, elevated, and properly categorized as high risk, and subject to enhanced due diligence and monitoring; and
+- (g) Sufficient quality control processes to ensure the surveillance and transaction monitoring system, alert management process, and SAR decisioning and filing are working effectively and according to internal standards.
+
+## ARTICLE VIII
+
+# SUSPICIOUS ACTIVITY REPORT REVIEW ("SAR LOOK-BACK")
+
+- (1) Within 30 days of this Order, the Banks shall provide to the Examiner-in-Charge for prior no supervisory objection an action plan to review the quality of SAR filings ("SAR look-back"). The purpose of the SAR look-back is to review the quality of SARs filed and determine whether corrections or amendments are necessary to ensure
+
+that the suspicious activity identified was accurately reported in accordance with 12 C.F.R. § 21.11, and whether additional SARs should be filed on additional subjects or for continuing suspicious activity.
+
+(2) The SAR look-back must be supervised and certified by independent consultant(s) acceptable to the Examiner-in-Charge with expertise in conducting lookback reviews for large institutions.
+
+(3) Upon completion of the SAR look-back: (i) the Bank shall ensure that SARs have been filed, in accordance with 12 C.F.R. § 21.11, for any previously reported suspicious activity identified during this review; (ii) the written findings shall be reported to the Board; and (iii) the Bank will provide the Examiner-in-Charge with a report, containing relevant information, including the number of modified or amended SARs and any additional or continuing activity SARs filed as a result of the review.
+
+(4) Based upon the results of the SAR look-back, the OCC may expand the scope of the independent review or require a longer SAR look-back period. If an additional SAR look-back is deemed appropriate by the OCC, the Bank shall complete the SAR look-back in accordance with this Article.
+
+# ARTICLE IX
+
+# ACCOUNT/TRANSACTION ACTIVITY AND SUSPICIOUS ACTIVITY REPORT REVIEW ("ACCOUNT AND TRANSACTION LOOK-BACK")
+
+(1) Within 30 days of this Order, the Bank shall provide to the Examiner-in-Charge for prior no supervisory objection an action plan to conduct an independently supervised review of account and transaction activity ("account and transaction lookback") covering non-bank financial institutions, as defined in the FFIEC BSA/AML Examination Manual.
+
+(2) The purpose of the account and transaction look-back is to determine whether suspicious activity was timely identified by the Bank, and, if appropriate to do so, was then timely reported by the Bank in accordance with 12 C.F.R. § 21.11.
+
+(3) The account and transaction look-back must be supervised and certified by independent consultant(s) with expertise in conducting look-back reviews for large institutions. The account and transaction look-back shall be risk-based, including the risks identified in the Bank's risk assessment as revised under Article V, and shall identify the sampling, software screening, or analytical techniques used to identify transactions that are subject to review for suspicious activity.
+
+(4) Upon completion of the account and transaction look-back: (i) the Bank shall ensure that SARs have been filed, in accordance with 12 C.F.R. § 21.11, for any previously unreported suspicious activity identified during this review; (ii) the written findings shall be reported to the Board; and (iii) the Bank will provide the Examiner-in-Charge with a report, containing relevant information, identifying any SARs filed as a result of previously unreported suspicious activity.
+
+(5) Based upon the results of the account and transaction look-back, the OCC may expand the scope of the independent review or require a longer account and transaction look-back period. If an additional account and transaction look-back is deemed appropriate by the OCC, the Bank shall complete the account and transaction look-back in accordance with this Article.
+
+#### ARTICLE X
+
+#### INDEPENDENT TESTING AND AUDIT
+
+(1) Within 90 days of this Order, the Bank shall develop and maintain an effective program to audit the Bank's BSA/AML and OFAC Compliance Programs ("Audit Program"). The Audit Program shall include, at a minimum:
+
+- (a) A formal process to track and report upon Bank management's remediation efforts to strengthen the Bank's BSA/AML/OFAC compliance program;
+- (b) Testing of the adequacy of internal controls designed to ensure compliance with BSA and OFAC, and their implementing regulations;
+- (c) A risk-based approach that focuses transactional testing on higherrisk clients, products, geographies, and significant relationships; and
+- (d) A requirement for prompt management response and follow-up to audit exceptions or other recommendations of the Bank's auditor.
+
+(2) The Audit Program shall evaluate internal controls and effectively and timely identify non-compliance with policy, laws, rules, and regulations across lines of business and within each line of business. At least annually, the Audit Program shall evaluate the adequacy of the Bank's BSA Program based on the results of the independent testing, and considering changes in the quantity of AML risk or AML risk management.
+
+(3) The Bank's audit function shall be adequately staffed with respect to experience level, specialty expertise regarding BSAJAML and OFAC, and number of the individuals employed.
+
+(4) The Bank's Audit Program shall report all internal audit- and OCCidentified deficiencies to the Compliance Committee, the Bank's Audit Committee, and to senior compliance management. The reports shall indicate the severity of the deficiencies, the risks, the corrective actions, and timeframes. Corrective actions must be followed-up by internal audit within a reasonable period of time until closed. Monthly status reports on corrective action status shall be provided to the Compliance Committee and the Bank's Audit Committee.
+
+(5) The Board and senior compliance management shall receive adequately detailed information about the Bank's compliance management program in light of their respective obligations to oversee the Bank and to fulfill their fiduciary responsibilities and other responsibilities under law. Deficiencies in the program shall be identified and highlighted along with the risks.
+
+(6) Within 90 days of this Order, the Bank shall submit the Audit Program to the Examiner-in-Charge for prior no supervisory objection. If the Examiner-in-Charge recommends changes to the Audit Program, the Bank shall incorporate those changes or suggest alternatives that are acceptable to the Examiner-in-Charge.
+
+#### ARTICLE XI
+
+#### NEW ACCOUNTS. PRODUCTS. SERVICES. OR MARKET
+
+#### SEGMENTS/INDUSTRIES
+
+(1) The Bank shall ensure that new products and services are subject to senior level compliance review and approval. These reviews must consider the quantity of BSA/AML and OFAC risk of the new product or service as well as the quality of risk management. At a minimum, these reviews must assess the ability of the Bank's compliance program to manage the risk, the anticipated growth in both the business and the compliance function, and the ability of alert investigators' to manage any anticipated increase in alert volume as a result of the new business.
+
+(2) The Bank shall not enter into a new high-risk (inherent quantity) market segment/industry, enter into new or expand existing high-risk (inherent quantity) lines of business, without conducting a risk assessment, a determination of compliance staffing impact, and without providing prior notification of at least 30 days to the Examiner-in-Charge of such proposed actions.
+
+#### ARTICLE XII
+
+#### APPROVAL. IMPLEMENTATION AND REPORTS
+
+(1) The Bank shall submit the written plans, programs, policies and procedures required by this Order for review and determination of no supervisory objection to the Deputy Comptroller and the Examiner-in-Charge within the applicable time periods set forth in Articles III through XI. The Board shall approve the submission and cause the Bank to submit the plans, programs, policies and procedures to the Deputy
+
+Comptroller and Examiner-in-Charge for prior written determination of no supervisory objection. In the event the Deputy Comptroller asks the Bank to revise the plans, programs, policies or procedures, the Board shall promptly make necessary and appropriate revisions and resubmit the materials to the Deputy Comptroller and Examiner-in-Charge for review and determination of no supervisory objection. Upon receiving written notice of no supervisory objection from the Deputy Comptroller, the Board promptly shall adopt the plans, programs, policies and procedures and direct and cause the Bank to implement and thereafter adhere to the plans, programs, policies and procedures. Following implementation of the plans, programs, policies and procedures, the Board shall ensure that the Bank does not take any action that will cause a significant deviation from, or material change to the plans, programs, policies and procedures, unless and until the Board has received prior written determination of no supervisory objection from the Deputy Comptroller.
+
+(2) During the term of this Order, the Bank shall revise the required plans, programs, policies and procedures as necessary to incorporate new, or changes to, applicable legal requirements and supervisory guidelines following the procedures above.
+
+(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the plans, programs, policies and procedures required by this Order.
+
+(4) Within thirty (30) days after the end of each calendar quarter following the date of this Order, the Bank shall submit to the OCC a written progress report detailing the form and manner of all actions taken to secure compliance with the provisions of this Order and the results thereof. The progress report shall include information sufficient to
+
+validate compliance with this Order, based on a testing program acceptable to the OCC that includes, if required by the OCC, validation by third-party independent consultants acceptable to the OCC. The OCC may, in writing, discontinue the requirement for progress reports or modify the reporting schedule.
+
+- (5) All communication regarding this Order shall be sent to:
+
+Sally G. Belshaw Deputy Comptroller Large Bank Supervision Office of the Comptroller of the Currency 250 E Street, SW Washington, DC 20219
+
+Scott N. Waterhouse Examiner-in-Charge National Bank Examiners 1166 Avenue of the Americas, 21' Floor New York, NY 10036
+
+or such other individuals or addresses as directed by the OCC.
+
+- (1) Although this Order requires the Bank to submit certain actions, plans, programs, policies and procedures for the review or prior written determination of no supervisory objection by the Deputy Comptroller or the Examiner-in-Charge, the Board has the ultimate responsibility for proper and sound management of the Bank.
+- (2) If, at any time, the Comptroller deems it appropriate in fulfilling the responsibilities placed upon him by the several laws of the United States to undertake any action affecting the Bank. nothing in this Order shall in any way inhibit, estop, bar or otherwise prevent the Comptroller from so doing.
+
+# ARTICLE XIII
+
+# CLOSING
+
+(3) This Order constitutes a settlement of the cease and desist proceeding against the Bank contemplated by the Comptroller, based on the unsafe or unsound practices and violations of law or regulation described in the Comptroller's Findings set forth in Article I of this Order. The OCC releases and discharges the Bank from all potential liability for a cease and desist order that has been or might have been asserted by the OCC based on the practices and violations described in the Comptroller's Findings set forth in Article I of the Order, to the extent known to the OCC as of the effective date of the Order. Provided, however, that nothing in the Stipulation or this Order shall prevent the Comptroller from instituting other enforcement actions against the Bank or any of its institution-affiliated parties, including, without limitation, assessment of civil money penalties, based on the findings set forth in this Order, or any other findings, and nothing in the Stipulation or this Order shall preclude or affect any right of the OCC to determine and ensure compliance with the terms and provisions of the Stipulation or this Order.
+
+(4) This Order is and shall become effective upon its execution by the Comptroller, through his authorized representative whose hand appears below. The Order shall remain effective and enforceable, except to the extent that, and until such time as, any provision of this Order shall be amended, suspended, waived, or terminated in writing by the Comptroller.
+
+(5) Any time limitations imposed by this Order shall begin to run from the effective date of this Order, as shown below, unless the Order specifies otherwise. The time limitations may be extended in writing by the Deputy Comptroller for good cause upon written application by the Board. Any request to extend any time limitation shall include a statement setting forth in detail the special circumstances that prevent the Bank from complying with the time limitation, and shall be accompanied by relevant supporting documentation. The Deputy Comptroller's decision regarding the request is final and not subject to further review.
+
+(6) The terms and provisions of this Order apply to JPMorgan Chase Bank, N.A., Columbus, ■; **JPMorgan Bank and Trust Company, N.A., San Francisco, CA; and Chase Bank USA, N.A., Newark, DE and all their subsidiaries, even though those subsidiaries are not named as parties to this Order. The Bank shall integrate any activities done by a subsidiary into its plans, policies, programs and processes required by this Order. The Bank shall ensure that its subsidiaries comply with all terms and provisions of this Order.** 
+
+**(7) This Order is intended to be, and shall be construed to be, a final order issued pursuant to 12 U.S.C. § 1818(b), and expressly does not form, and may not be construed to form, a contract binding the Comptroller or the United States. Without limiting the foregoing, nothing in this Order shall prevent any action against the Bank or its institution-affiliated parties by a bank regulatory agency, the United States Department of Justice, or any other law enforcement agency.** 
+
+**(8) The terms of this Order, including this paragraph, are not subject to amendment or modification by any extraneous expression, prior agreements, or prior arrangements between the parties, whether oral or written.** 
+
+**IT IS SO ORDERED. this 14 day of Jan , 2013.** 
+
+**Is/** 
+
+**Sally G. Belshaw Deputy Comptroller for Large Bank Supervision Office of the Comptroller of the Currency** 
+
+#### UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY COMPTROLLER OF THE CURRENCY
+
+)
+
+In the Matter of: )
+
+)
+
+JPMorgan Chase Bank, N.A. ) Columbus, )
+
+)
+
+JPMorgan Bank and Trust Company, N.A. ) San Francisco, CA )
+
+)
+
+Chase Bank USA, N.A. ) Newark, DE ) AA-EC-13-04
+
+# STIPULATION AND CONSENT TO THE ISSUANCE OF A CONSENT ORDER
+
+WHEREAS, the Comptroller of the Currency of the United States of America ("Comptroller"), based upon information derived from the exercise of his regulatory and supervisory responsibilities, intends to issue a cease and desist order to JPMorgan Chase Bank, N.A., Columbus, Ohio; JPMorgan Bank and Trust Company, N.A., San Francisco, California; and Chase Bank USA, N.A., Newark, Delaware, and their subsidiaries (collectively referred to as "Bank"), pursuant to 12 U.S.C. § 1818(b), for violations of 12 U.S.C. § 1818(s), and Bank Secrecy Act regulations, 12 C.F.R. §§ 21.11 and 21.21;
+
+WHEREAS, in the interest of cooperation and to avoid additional costs associated with administrative and judicial proceedings with respect to the above matter, the Bank, through its duly elected and acting Boards of Directors (collectively referred to as "Board"), has agreed to
+
+execute this Stipulation and Consent to the Issuance of a Consent Order ("Stipulation"), that is accepted by the Comptroller, through his duly authorized representative;
+
+NOW, THEREFORE, in consideration of the above premises, it is stipulated by the Bank that:
+
+#### ARTICLE I
+
+#### JURISDICTION
+
+- (1) The Bank is a national banking association chartered and examined by the Comptroller pursuant to the National Bank Act of 1864, as amended, 12 U.S.C. § 1 et seq.
+- (2) The Comptroller is "the appropriate Federal banking agency" regarding the Bank pursuant to 12 U.S.C. §§ 1813(q) and 1818(b).
+- (3) The Bank is an "insured depository institution" within the meaning of 12 U.S.C. § 1818(6)(1).
+
+- (1) The Bank, without admitting or denying any wrongdoing, consents and agrees to issuance of the accompanying Consent Order by the Comptroller.
+- (2) The terms and provisions of the Consent Order apply to JPMorgan Chase Bank, N.A., Columbus,. JPMorgan Bank and Trust Company, N.A., San Francisco, CA; and Chase Bank USA, N.A., Newark, DE and all their subsidiaries, even though those subsidiaries are not named as parties to the Consent Order.
+- (3) The Bank consents and agrees that the Consent Order shall be deemed an "order issued with the consent of the depository institution" pursuant to 12 U.S.C. § 1818(h)(2), will
+
+# ARTICLE II
+
+# CONSENT
+
+become effective upon its execution by the Comptroller through his authorized representative, and will be fully enforceable by the Comptroller pursuant to 12 U.S.C. § 1818(b).
+
+(4) Notwithstanding the absence of mutuality of obligation, or of consideration, or of a contract, the Comptroller may enforce any of the commitments or obligations herein undertaken by the Bank under his supervisory powers, including 12 U.S.C. § 1818(b), and not as a matter of contract law. The Bank expressly acknowledges that neither the Bank nor the Comptroller has any intention to enter into a contract.
+
+(5) The Bank declares that no separate promise or inducement of any kind has been made by the Comptroller, or by his agents or employees, to cause or induce the Bank to consent to the issuance of the Consent Order and/or execute this Stipulation.
+
+(6) The Bank expressly acknowledges that no officer or employee of the Comptroller has statutory or other authority to bind the United States, the United States Treasury Department. the Comptroller, or any other federal bank regulatory agency or entity, or any officer or employee of any of those entities to a contract affecting the Comptroller's exercise of his supervisory responsibilities.
+
+(7) The Consent Order constitutes a settlement of the cease and desist proceeding against the Bank contemplated by the Comptroller, based on the unsafe or unsound practices and violations of law or regulation described in the Comptroller's Findings set forth in Article I of the Consent Order. The OCC releases and discharges the Bank from all potential liability for a cease and desist order that has been or might have been asserted by the OCC based on the practices and violations described in the Comptroller's Findings set forth in Article I of the Consent Order, to the extent known to the OCC as of the effective date of the Order. Provided however, that nothing in this Stipulation or the Consent Order shall prevent the Comptroller from instituting other enforcement actions against the Bank or any of its institution-affiliated parties, including, without limitation, assessment of civil money penalties, based on the findings set forth in the Consent Order, or any other findings, and nothing in the Consent Order shall preclude or affect any right of the OCC to determine and ensure compliance with the terms and provisions of this Stipulation or the Consent Order.
+
+(8) The terms and provisions of the Stipulation and the Consent Order shall be binding upon, and inure to the benefit of, the parties hereto and their successors in interest. Nothing in this Stipulation or the Consent Order, express or implied, shall give to any person or entity, other than the parties hereto, and their successors hereunder, any benefit or any legal or equitable right, remedy or claim under this Stipulation or the Consent Order.
+
+# ARTICLE III
+
+# WAIVERS
+
+(1) The Bank, by executing this Stipulation and consenting to the Consent Order, waives:
+
+- (a) Any and all rights to the issuance of a Notice of Charges pursuant to 12 U.S.C. § 1818(b);
+- (b) Any and all procedural rights available in connection with the issuance of the Consent Order;
+- (c) Any and all rights to a hearing and a final agency decision pursuant to 12 U.S.C. §§ 1818(b) and (h), and 12 C.F.R. Part 19;
+- (d) Any and all rights to seek any type of administrative or judicial review of the Consent Order;
+
+- (e) Any and all claims for fees, costs or expenses against the Comptroller, or any of his agents or employees, related in any way to this enforcement matter or the Consent Order, whether arising under common law or under the terms of any statute, including, but not limited to, the Equal Access to Justice Act, 5 U.S.C. § 504 and 28 U.S.C. § 2412; (0 Any and all rights to assert this proceeding, this Stipulation, consent to the issuance of the Consent Order, and/or the issuance of the Consent Order, as the basis for a claim of double jeopardy in any pending or future proceeding brought by the United States Department of Justice or any other governmental entity; and
+- (g) Any and all rights to challenge or contest the validity of the Consent Order.
+
+# ARTICLE IV
+
+# ELIGIBLE BANK — OTHER PROVISIONS
+
+- (1) As a result of the Consent Order
+  - (a) The Bank is an "eligible bank" pursuant to 12 C.F.R. § 5.3(.g)(4) for the purposes of 12 C.F.R. Part 5 regarding rules, policies and procedures for corporate activities, unless otherwise informed in writing by the OCC;
+  - (b) The Bank is not subject to the limitation of 12 C.F.R. § 5.51(c)(6)(ii) for the purposes of 12 C.F.R. § 5.51 requiring OCC approval of a change in directors and senior executive officers, unless otherwise informed in writing by the OCC;
+
+- (c) The Bank is not subject to the limitation on golden parachute and indemnification payments provided by 12 C.F.R. § 359.1(f)(1)(ii)(C) and 12 C.F.R. § 5.51(c)(6)(ii), unless otherwise informed in writing by the OCC;
+- (d) The Bank's status as an "eligible bank" remains unchanged pursuant to 12 C.F.R. § 24.2(e)(4) for the purposes of 12 C.F.R. Part 24 regarding community and economic development, unless otherwise informed in writing by the OCC; and
+- (e) The Consent Order shall not be construed to be a "written agreement, order, or capital directive" within the meaning of 12 C.F.R. § 6.4, unless the OCC informs the Bank otherwise in writing.
+
+# ARTICLE V
+
+# CLOSING
+
+- (1) The provisions of this Stipulation and the Consent Order shall not inhibit, estop, bar, or otherwise prevent the Comptroller from taking any other action affecting the Bank if, at any time, it deems it appropriate to do so to fulfill the responsibilities placed upon it by the several laws of the United States of America.
+- (2) Nothing in this Stipulation or the Consent Order shall preclude any proceedings brought by the Comptroller to enforce the terms of the Consent Order, and nothing in this Stipulation or the Consent Order constitutes, nor shall the Bank contend that it constitutes, a release, discharge, compromise, settlement, dismissal, or resolution of any actions, or in any way affects any actions, that may be or have been brought by any other representative of the United
+
+States or an agency thereof, including, without limitation, the United States Department of Justice.
+
+(3) The terms of this Stipulation, including this paragraph, and of the Consent Order are not subject to amendment or modification by any extraneous expression, prior agreements or prior arrangements between the parties, whether oral or written.
+
+IN TESTIMONY WHEREOF, the undersigned, as the duly elected and acting Board of Directors of JPMorgan Chase Bank, N.A., Columbus,. have hereunto set their hands on behalf of the Bank.
+
+/s/ 01/14/13 II. J. Bisignano Date
+
+/s/ 01/14/13 James S. Crown Date
+
+/s/ 01/14/13 James Dimon Date
+
+/s/ 01/14/13 Laban P. Jr. Date
+
+/s/ 01/14/13 Marianne Lake Date
+
+IN TESTIMONY WHEREOF, the undersigned, as the duly elected and acting Board of Directors of JPMorgan Bank and Trust Company, N.A., San Francisco, CA, have hereunto set their hands on behalf of the Bank.
+
+/s/ \_\_\_\_\_  
+Brent L. Barton
+
+01/14/2013  
+Date
+
+/s/ \_\_\_\_\_  
+John J. Hyland
+
+01/14/2013  
+Date
+
+/s/ \_\_\_\_\_  
+Kelly A. Mathieson
+
+01/14/2013  
+Date
+
+/s/ \_\_\_\_\_  
+Jennifer A. Piepszak
+
+01/14/2013  
+Date
+
+/s/ \_\_\_\_\_  
+Daniel J. Riner
+
+01/14/2013  
+Date
+
+IN TESTIMONY WHEREOF, the undersigned, as the duly elected and acting Board of Directors of Chase Bank USA, N.A., Newark, DE, have hereunto set their hands on behalf of the Bank.
+
+/s/ 01/14/2013 Raymond Fischer Date
+
+/s/ 01/14/2013 Catherine M. Hogan Date
+
+/s/ 01/14/2013 Matthew Kane Date
+
+/s/ 01/14/2013 James K. Paterson Date
+
+/s/ 01/14/2013 Keith W. Schuck Date
+
+/s/ 01/14/2013 Eileen M. IMI Date
+
+/s/ 01/14/2013 John C. Marion Date
+
+Accepted by:
+
+# THE COMPTROLLER OF THE CURRENCY
+
+By: /s/
+
+01/14/2013
+
+Sally G. Belshaw Date Deputy Comptroller for Large Bank Supervision Office of the Comptroller of the Currency
\ No newline at end of file
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+# EXHIBIT 2
+
+#2014-001
+
+#### UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY COMPTROLLER OF THE CURRENCY
+
+)
+
+In the Matter of: )
+
+)
+
+JPMorgan Chase Bank, N.A. ) Columbus, El )
+
+)
+
+JPMorgan Bank and Trust Company, N.A. ) San Francisco, CA )
+
+)
+
+Chase Bank USA, N.A. ) Wilmington, DE ) AA-EC-13-109
+
+# CONSENT ORDER FOR THE ASSESSMENT OF A CIVIL MONEY PENALTY
+
+The Comptroller of the Currency of the United States of America ("Comptroller"), through his national bank examiners and other staff of the Office of the Comptroller of the Currency ("OCC), has conducted examinations of JPMorgan Chase Bank, N.A., Columbus, Ohio; JPMorgan Bank and Trust Company, N.A., San Francisco, California; and Chase Bank USA, N.A., Wilmington, Delaware (collectively referred to as "Bank"). The OCC has identified deficiencies in the Bank's Bank Secrecy Act/anti-money laundering ("BSA/AML") compliance program, resulting in violations of 31 U.S.C. § 5318(i) and its implementing regulation, 31 C.F.R. § 1010.610(a), (b) and (c); 12 U.S.C. § 1818(s) and its implementing regulation, 12 C.F.R. § 21.21(c); and 12 C.F.R. § 21.11(c) and (d). The Bank is also the subject of a prior OCC Consent Cease and Desist Order issued on January 14, 2013 ("January 2013 Order").
+
+Examinations conducted subsequent to the issuance of the January 2013 Order have revealed additional deficiencies in the Bank's BSA/AML compliance program, which resulted in the citation of additional violations of law and regulation. The Bank has been notified of the findings of these examinations.
+
+The Bank, by and through its duly elected and acting Boards of Directors, has executed a "Stipulation and Consent to the Issuance of a Consent Order for the Assessment of a Civil Money Penalty," dated January 7, 2014, that is accepted by the Comptroller ("Stipulation"). By this Stipulation, which is incorporated herein by reference, the Bank has consented to the issuance of this Consent Order for the Assessment of a Civil Money Penalty ("Consent Order") by the Comptroller.
+
+On January 6, 2014, the Bank entered into a Deferred Prosecution Agreement ("DPA") with the United States Attorney's Office for the Southern District of New York. In the DPA, the Bank admitted to certain facts concerning the failure to file a Suspicious Activity Report ("SAW') in the United States on Bernard L. Madoff Investment Securities, LLC ("Madoff).
+
+# ARTICLE I
+
+# COMPTROLLER'S FINDINGS
+
+The Comptroller finds the following:
+
+The Comptroller incorporates the following findings from Article I of the January 2013 Order:
+
+- (I) The OCC's examination findings establish that the Bank has deficiencies in its BSA/AML compliance program. These deficiencies have resulted in the failure to correct a previously reported problem and a BSA/AML compliance program violation under 12 U.S.C. § 1818(s) and its implementing regulation, 12 C.F.R. § 21.21 (BSA Compliance
+
+Program). In addition, the Bank has violated 12 C.F.R. § 21.11 (Suspicious Activity Report Filings).
+
+(2) The Bank has failed to adopt and implement a compliance program that adequately covers the required BSA/AML program elements due to an inadequate system of internal controls and ineffective independent testing. The Bank did not develop adequate due diligence on customers, particularly in the Commercial and Business Banking Unit, a repeat problem, and failed to file all necessary SARs related to suspicious customer activity.
+
+(3) The Bank failed to correct previously identified systemic weaknesses in the adequacy of customer due diligence and the effectiveness of monitoring in light of the customers' cash activity and business type, constituting a deficiency in its BSA/AML compliance program and resulting in a violation of 12 U.S.C. § 1818(s)(3)(B).
+
+(4) Some of the critical deficiencies in the elements of the Bank's BSA/AML compliance program, resulting in a violation of 12 U.S.C. § 1818(sX3)(A) and 12 C.F.R. § 21.21, include the following:
+
+(a) The Bank has an inadequate system of internal controls and independent testing.
+
+(b) The Bank has less than satisfactory risk assessment processes that do not provide an adequate foundation for management's efforts to identify, manage, and control risk.
+
+(c) The Bank has systemic deficiencies in its transaction monitoring systems, due diligence processes, risk management, and quality assurance programs.
+
+(d) The Bank does not have enterprise-wide policies and procedures to ensure that foreign branch suspicious activity involving customers of other bank branches is effectively communicated to other affected branch locations and applicable AML operations staff. The
+
+Bank also does not have enterprise-wide policies and procedures to ensure that on a risk basis, customer transactions at foreign branch locations can be assessed, aggregated, and monitored.
+
+(e) The Bank has significant shortcomings in SAR decision-making protocols and an ineffective method for ensuring that referrals and alerts are properly documented, tracked, and resolved.
+
+(5) The Bank failed to identify significant volumes of suspicious activity and file the required SARs concerning suspicious customer activities, in violation of 12 C.F.R. § 21.11. In some of these cases, the Bank self-identified the issues and is engaged in remediation.
+
+(6) The Bank's internal controls, including filtering processes and independent testing, with respect to Office of Foreign Asset Control ("OFAC") compliance are inadequate.
+
+The Comptroller further finds, for purposes of this Consent Order:
+
+(7) The Bank has not established adequate BSA/AML and due diligence programs for its foreign branches, offices, or affiliates in violation of 31 U.S.C. § 53I8(i) (implementing Section 312 of the USA PATRIOT Act, Pub. L. No. 107-56, § 312(a), 115 Stat. 272, 312 (2001)), and 12 C.F.R. § 21.21(c). This violation includes the Bank's failure to conduct suspicious activity monitoring of transactions between the Bank and certain of the Bank's affiliates.
+
+(8) The Bank did not establish and implement an adequate BSA/AML program for correspondent banking and remote deposit capture ("RDC") and international cash letter ("ICU') products or adequate internal controls, including the Bank's due diligence programs, in the correspondent banking and RDC/ICL areas. Inadequate controls resulted in certain special accommodation clients in the Bank that operated outside of the normal AML monitoring and OFAC screening controls. For these reasons, the Bank is in violation of 31 U.S.C. § 5318(i),
+
+12 U.S.C. § 1818(s), 12 C.F.R. § 21.21(c), and 31 C.F.R. § 1010.610(a), (b), and (c). These failures also caused the Bank to fail to file SARs and to do so timely in violation of 12 C.F.R. § 21.11(c) and (d).
+
+(9) The Bank has failed to correct previously reported problems in several areas, including Asia Private Banking, and with respect to one of its correspondent bank relationships, resulting in additional violations of 12 U.S.C. § 1818(s).
+
+(10) The Bank's SAR filing processes and procedures for SAR filing in the areas of Chase Auto Finance and Student Lending were inadequate, and the Bank further failed in certain instances to file SARs related to suspected fraud by employees, resulting in violations of 12 C.F.R. § 21.11(c).
+
+(11) Between 2006 and 2008, the Bank created, sold and made a secondary market for structured products that provided customers access to Madofrs investment strategy through several "feeder funds." Prior to Bernard L. Madofrs arrest, the Bank developed concerns about Madoff and a distributor of Madoff-linked investments created by the Bank. These concerns caused the Bank's London branch to file a suspicious activity report with the United Kingdom's Serious Organised Crime Agency on October 29, 2008. Aware that Madoff was a client of the Bank in the U.S., U.K.-based Bank employees conveyed these concerns to U.S.-based Bank employees. Despite the fact that these concerns caused the Bank to file a suspicious activity report in the U.K., the Bank did not file a SAR in the U.S. based on these concerns. The failure to file a SAR on this activity and to do so timely is significant and a violation of 12 C.F.R. § 21.11(c) and (d).
+
+(12) The Bank maintained a correspondent banking relationship with a Puerto-Ricanchartered affiliate of a Venezuelan bank. Although the Bank filed SARs relating to this
+
+correspondent account, the Bank did not investigate additional suspicious activity, totaling over \$2 billion, pertaining to counterparties that flowed through the account at the Bank. The failure to file SARs on this activity and to do so timely is significant and in violation of 12 C.F.R. § 21.II(c) and (d).
+
+(13) From 2004 to 2010, the Bank failed to adequately monitor, investigate and file SARs on approximately \$450 million of suspicious bulk cash transactions in an account at the Bank for another of its correspondents. The failure to file SARs on this activity and to do so timely is significant and in violation of 12 C.F.R. § 21.11(c) and (d).
+
+(14) From February 2013 to March 2013, the Bank failed to adequately monitor and file a supplemental SAR on ongoing activity relating to \$471,680 in suspicious transactions in an account at the Bank for a third correspondent. The failure to file SARs on this activity and to do so timely is significant and in violation of 12 C.F.R. § 21.11(c) and (d).
+
+# ARTICLE II
+
+# ORDER FOR A CIVIL MONEY PENALTY
+
+Pursuant to the authority vested in him by the Federal Deposit Insurance Act, 12 U.S.C. § 1818(i), the Comptroller orders, and the Bank consents to, the following:
+
+(1) The Bank shall make payment of a civil money penalty in the total amount of three hundred and fifty million dollars (\$350,000,000), which shall be paid upon the execution of this Consent Order:
+
+- (a) If a check is the selected method of payment, the check shall be made payable to the Treasurer of the United States and shall be delivered to:
+
+Comptroller of the Currency, P.O. Box 979012, St. Louis, Missouri 63197-9000.
+
+- (b) If a wire transfer is the selected method of payment, it shall be sent in accordance with instructions provided by the Comptroller.
+- (c) The docket number of this case (AA-EC-I3-109) shall be entered on the payment document or wire confirmation and a photocopy of the payment document or confirmation of the wire transfer shall be sent immediately, by overnight delivery, to the Director of Enforcement and Compliance, Office of the Comptroller of the Currency, 400 7th Street, S.W., Washington, D.C. 20219.
+
+(2) This Consent Order shall be enforceable to the same extent and in the same manner as an effective and outstanding order that has been issued and has become final pursuant to 12 U.S.C. § I 8I8(h) and (i).
+
+# ARTICLE III
+
+# OTHER PROVISIONS
+
+(1) This Consent Order is intended to be, and shall be construed to be, a final order issued pursuant to 12 U.S.C. § 1818(i)(2), and expressly does not form, and may not be construed to form, a contract binding on the Comptroller or the United States.
+
+(2) This Consent Order constitutes a settlement of the civil money penalty proceeding against the Bank contemplated by the Comptroller, based on the violations of law and regulation described in the Comptroller's Findings set forth in Article I of this Consent Order. The OCC releases and discharges the Bank from all potential liability for a civil money penalty that has
+
+been or might have been asserted by the Comptroller based solely on the violations of law and regulation as described in the referenced findings, to the extent known to the Comptroller as of the effective date of the Consent Order. Provided, however, that nothing in the Stipulation or this Consent Order shall prevent the Comptroller from instituting enforcement actions against the Bank or any of its institution-affiliated parties, including, without limitation, assessment of civil money penalties, based on any other findings, including, but not limited to, findings related to required look backs or reviews conducted by or on behalf of the Bank. The violations of law and regulation described in Article I of this Consent Order may be utilized by the Comptroller in other future enforcement actions against the Bank or its institution-affiliated parties, including, without limitation, to establish a pattern or practice of violations or unsafe and unsound practices, or the continuation of a pattern or practice of violations or unsafe or unsound practices. Nothing in this Consent Order shall preclude or affect any right of the Comptroller to determine and ensure compliance with the terms and provisions of the Stipulation or this Consent Order.
+
+(3) The terms of this Consent Order, including this paragraph, are not subject to amendment or modification by any extraneous expression, prior agreements, or prior arrangements between the parties, whether oral or written.
+
+IT IS SO ORDERED, this 7th day of January 2014.
+
+14orris R.
+
+Deputy Comptroller
+
+Large Bank Supervision
+
+#### UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY COMPTROLLER OF THE CURRENCY
+
+) In the Matter of: ) ) JPMorgan Chase Bank, N.A. ) Columbus, ) ) JPMorgan Bank and Trust Company, N.A. ) San Francisco, CA ) ) Chase Bank USA, N.A. ) Wilmington, DE ) ) ) AA-EC-13-109
+
+#### STIPULATION AND CONSENT TO THE ISSUANCE OF A CONSENT ORDER FOR THE ASSESSMENT OF A CIVIL MONEY PENALTY
+
+The Comptroller of the Currency of the United States of America ("Comptroller"), based upon information derived from the exercise of his regulatory and supervisory responsibilities, intends to initiate a civil money penalty ("CMP") proceeding against JPMorgan Chase Bank, N.A., Columbus, Ohio; JPMorgan Bank and Trust Company, N.A., San Francisco, California; and Chase Bank USA, N.A., Wilmington, Delaware (collectively referred to as "Bank"), pursuant to 12 U.S.C. § 1818(i), based on serious deficiencies in the Bank's Bank Secrecy Act/anti-money laundering ("BSA/AML") compliance program and violations of Suspicious Activity Reporting laws and regulations.
+
+In the interest of cooperation and to avoid additional costs associated with administrative and judicial proceedings with respect to the above matter, and without an adjudication on the merits, the Bank, through its duly elected and acting Boards of Directors ("Boards"), has agreed to execute this Stipulation and Consent to the Issuance of a Consent Order for the Assessment of a Civil Money Penalty ("Stipulation"), that is accepted by the Comptroller, through his duly authorized representative.
+
+In consideration of the above premises, it is stipulated by the Bank that:
+
+# ARTICLE I
+
+#### JURISDICTION
+
+- (1) The Bank is a national banking association chartered and examined by the Comptroller pursuant to the National Bank Act of 1864, as amended, 12 U.S.C. § 1 et seq.
+- (2) The Comptroller is "the appropriate Federal banking agency" regarding the Bank pursuant to 12 U.S.C. §§ 1813(q) and 1818(i).
+- (3) The Bank is an "insured depository institution" within the meaning of 12 U.S.C. § 1818(i).
+
+# ARTICLE II
+
+## CONSENT
+
+- (1) The Bank consents and agrees to issuance of the accompanying Consent Order for the Assessment of a Civil Money Penalty ("Consent Order") by the Comptroller.
+- (2) The terms and provisions of the Consent Order apply to JPMorgan Chase Bank, N.A., Columbus, Ohio; JPMorgan Bank and Trust Company, N.A., San Francisco, California; and Chase Bank USA, N.A., Wilmington, Delaware; and all their subsidiaries, even though those subsidiaries are not named as parties to the Consent Order.
+- (3) The Bank consents and agrees that the Consent Order shall be deemed an "order issued with the consent of the depository institution" pursuant to 12 U.S.C. § 1818(h)(2), and
+
+consents and agrees that the Consent Order shall become effective upon its execution by the Comptroller through his authorized representative, and shall be fully enforceable by the Comptroller pursuant to 12 U.S.C. § 1818(i).
+
+(4) Notwithstanding the absence of mutuality of obligation, or of consideration, or of a contract, the Comptroller may enforce any of the commitments or obligations herein undertaken by the Bank under his supervisory powers, including 12 U.S.C. § 1818(1), and not as a matter of contract law. The Bank expressly acknowledges that neither the Bank nor the Comptroller has any intention to enter into a contract.
+
+(5) The Bank expressly acknowledges that no separate promise or inducement of any kind has been made by the Comptroller, or by his agents or employees, to cause or induce the Bank to consent to the issuance of the Consent Order and/or execute this Stipulation.
+
+(6) The Bank expressly acknowledges that no officer or employee of the Comptroller has statutory or other authority to bind the United States, the United States Treasury Department, the Comptroller, or any other federal bank regulatory agency or entity, or any officer or employee of any of those entities to a contract affecting the Comptroller's exercise of his supervisory responsibilities.
+
+(7) The Consent Order constitutes a settlement of the CMP proceeding against the Bank contemplated by the Comptroller, based on the violations of law and regulation described in the Comptroller's Findings set forth in Article I of the Consent Order. The OCC releases and discharges the Bank from all potential liability for a CMP that has been or might have been asserted by the Comptroller based solely on the violations of law and regulation as described in the referenced findings, to the extent known to the Comptroller as of the effective date of the Consent Order. Provided, however, that nothing in this Stipulation or the Consent Order shall
+
+prevent the Comptroller from instituting enforcement actions against the Bank or any of its institution-affiliated parties, including, without limitation, assessment of CMPs, based on any other findings, including, but not limited to, findings related to required look backs or reviews conducted by or on behalf of the bank. The violations of law and regulation described in Article I of the Consent Order may be utilized by the Comptroller in other future enforcement actions against the Bank or its institution-affiliated parties, including, without limitation, to establish a pattern or practice of violations or unsafe and unsound practices, or the continuation of a pattern or practice of violations or unsafe or unsound practices. Nothing in the Consent Order shall preclude or affect any right of the Comptroller to determine and ensure compliance with the terms and provisions of this Stipulation, the Consent Order, or the prior OCC Consent Cease and Desist Order issued on January 14, 2013 ("January 2013 Order").
+
+- (1) waives: The Bank, by executing this Stipulation and consenting to the Consent Order,
+
+## ARTICLE III
+
+#### WAIVERS
+
+- (a) Any and all rights to the issuance of a Notice of Charges pursuant to 12 U.S.C. § 1818(i);
+- (b) Any and all procedural rights available in connection with the issuance of the Consent Order;
+- (c) Any and all rights to a hearing and a final agency decision pursuant to 12 U.S.C. § 1818(i) and 12 C.F.R. Part 19;
+
+- (d) Any and all rights to seek any type of administrative or judicial review of the Consent Order;
+- (e) Any and all claims for fees, costs or expenses against the Comptroller, or any of his agents or employees, related in any way to this enforcement matter or the Consent Order, whether arising under common law or under the terms of any statute, including, but not limited to, the Equal Access to Justice Act, 5 U.S.C. § 504 and 28 U.S.C. § 2412;
+- (f) Any and all rights to assert this proceeding, this Stipulation, consent to the issuance of the Consent Order, and/or the issuance of the Consent Order, as the basis for a claim of double jeopardy in any pending or future proceeding brought by the United States Department of Justice or any other governmental entity; and
+- (g) Any and all rights to challenge or contest the validity of the Consent Order.
+
+# ARTICLE IV
+
+#### CLOSING
+
+- (1) The provisions of this Stipulation and the Consent Order shall not inhibit, estop, bar, or otherwise prevent the Comptroller from taking any other action affecting the Bank if, at any time, he deems it appropriate to do so to fulfill the responsibilities placed upon him by the several laws of the United States of America.
+- (2) Nothing in this Stipulation or the Consent Order shall preclude any proceedings brought by the Comptroller to enforce the terms of the Consent Order or the January 2013 Order,
+
+and nothing in this Stipulation or the Consent Order constitutes, nor shall the Bank contend that it constitutes, a release, discharge, compromise, settlement, dismissal, or resolution of any actions, or in any way affects any actions that may be or have been brought by any other representative of the United States or an agency thereof, including, without limitation, the United States Department of Justice.
+
+(3) The terms of this Stipulation and the Consent Order are not subject to amendment or modification by any extraneous expression, prior agreements or prior arrangements between the parties, whether oral or written.
+
+IN TESTIMONY WHEREOF, the undersigned as the duly elected and acting Board of Directors of JPMorgan Chase Bank, N.A., Columbus, i have hereunto set their hands on behalf of the Bank.
+
+/s/ January 7, 2014 James S. Crown Date
+
+/s/ January 7, 2014 Laban P. Jr. Date
+
+/s/ January 7, 2014 Marianne Lake Date
+
+/s/ January 7, 2014 William C. Weldon Date
+
+/s/ January 7, 2014 Matthew E. Zames Date
+
+IN TESTIMONY WHEREOF, the undersigned, as the duly elected and acting Board of Directors of JPMorgan Bank and Trust Company, N.A., San Francisco, CA, have hereunto set their hands on behalf of the Bank.
+
+/s/ Brent L. Barton
+
+/s/ John J. Hyland
+
+/s/ Kelly A. Mathieson
+
+/s/ Jennifer A. Piepszak
+
+/s/ Daniel J. Riner January 7, 2014 Date
+
+January 7, 2014 Date
+
+January 7.2014 Date
+
+January 7.2014 Date
+
+January 7.2014 Date
+
+IN TESTIMONY WHEREOF, the undersigned, as the duly elected and acting Board of Directors of Chase Bank USA, N.A., Wilmington, DE, have hereunto set their hands on behalf of the Bank.
+
+/s/ Raymond Fischer
+
+/s/ Catherine M. Hogan Date
+
+January 7, 2014 Date
+
+January 7, 2014
+
+/s/ January 7, 2014 Matthew Kane Date
+
+/s/ January 7, 2014 James K. Paterson Date
+
+/s/ January 7, 2014 Samuel Todd Maclin Date
+
+/s/ January 7, 2014 Eileen M. Date
+
+/s/ January 7, 2014 John C. Marion Date
+
+Accepted by:
+
+# THE COMPTROLLER OF THE CURRENCY
+
+/s/ January 7, 2017 By: Morris It Deputy Comptroller Large Bank Supervision
+
+Date
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diff --git a/marker2/court-pension-v-dimon/EFTA02823147/EFTA02823147.md b/marker2/court-pension-v-dimon/EFTA02823147/EFTA02823147.md
new file mode 100644
index 0000000000000000000000000000000000000000..ee629b7b11d48e90323ed6eeb4e52b5ad7609d6c
--- /dev/null
+++ b/marker2/court-pension-v-dimon/EFTA02823147/EFTA02823147.md
@@ -0,0 +1,23 @@
+## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+Case No. 1:23-CV-03903 (JSR) DERIVATIVE ACTION
+
+## DECLARATION OF CHRISTINE M. MACKINTOSH IN SUPPORT OF PLAINTIFFS' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANTS' MOTIONS TO DISMISS
+
+CHRISTINE M. MACKINTOSH declares the following pursuant to 28 U.S.C. §1746:
+
+I. 1 am a Principal at the law firm of Grant & Eisenhofer P.A., 123 S. Justison Street, Wilmington, Delaware, attorneys for Plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund. I submit this declaration in support of Plaintiffs' Memorandum of Law in Opposition to Defendants' Motions to Dismiss.
+
+2. Attached hereto as Exhibit 1 is a true and correct copy of the Consent Order entered into between the Comptroller of the Currency of the United States of America and JPMorgan Chase Bank, N.A., JPMorgan Bank and Trust Company, N.A., and Chase Bank USA, N.A., dated January 14, 2013.
+
+3. Attached hereto as Exhibit 2 is a true and correct copy of the Consent Order for the Assessment of a Civil Money Penalty entered into between the Comptroller of the Currency of the United States of America and JPMorgan Chase Bank, N.A., JPMorgan Bank and Trust Company, N.A., and Chase Bank USA, N.A., dated January 4, 2014.
+
+I declare under penalty of perjury that the foregoing is true and correct.
+
+Executed on: July 20, 2023 Wilmington, Delaware
+
+Is/ Christine M Mackintosh
+
+Christine M. Mackintosh (admitted pro hac vice)
\ No newline at end of file
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+## UNITED STATES DISTRICT COURT
+
+for the
+
+Southern District of New York
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND and
+
+CITY OF MIAMI GENERAL EMPLOYEES & SANITATION ESIPLOYEESRETIREMENT TRUST
+
+Plaintiff
+
+v.
+
+JAMES DEMON. STEPHEN M.TODD A. COMBS. JAMES S. CROWN. TIMOTHY P. FLYNN.
+
+MELLOW HOBSON. JOHN W. KESSLER. PHEBEN. NOVAKOVIC. aeJ JAMES E. STALEY.
+
+Defendant
+
+Case No. 1:23-cv-03903-JSR
+
+## APPEARANCE OF COUNSEL
+
+To: The clerk of court and all parties of record
+
+I am admitted or otherwise authorized to practice in this court, and I appear in this case as counsel for:
+
+CITY OF MIAMI GENERAL EMPLOYEES & SANITATION EMPLOYEES RETIREMENT TRUST
+
+Date: 07/27/2023 /s/ Michael D. Blatchley
+
+Attorney's signature
+
+Michael D. Blatchley MB7279
+
+Printed name and bar number
+
+Bernstein Litowitz Berger & Grossmann LLP
+
+1251 Avenue of the Americas
+
+New York, NY 10020
+
+Address
+
+michaelb@blbglaw.com
+
+E-mail address
+
+(212) 554-1400
+
+Telephone number
+
+(212) 554-1444
+
+FAX number
\ No newline at end of file
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+## UNITED STATES DISTRICT COURT
+
+for the
+
+Southern District of New York
+
+OPERATING ENGINEERSCONSERV-RON INDUSTRY AND MISCELLANEOUS PENSION FUND
+
+am! CITY OF MIAMI ODIUM EMPLOYEES & SANITATION EMPLOYEEZRETIREMENT TRUST Plaintiff v.
+
+JAMES DEMON. STEPHEN I `TODD A. COMBS. JAMES S. momTIMOTHY P. FLYNN. MELLOW HOBSONJOHN W. KESSLER. PHEBEN. NOVAKOVIC. d JAMES E. STALEY. Defendant
+
+Case No. 1:23-cv-03903•JSR
+
+## APPEARANCE OF COUNSEL
+
+To: The clerk of court and all parties of record
+
+I am admitted or otherwise authorized to practice in this court, and I appear in this case as counsel for:
+
+CITY OF MIAMI GENERAL EMPLOYEES & SANITATION EMPLOYEES RETIREMENT TRUST
+
+Date: 07/27/2023 /s/ Jeroen van Kwawegen
+
+Attorney's signature
+
+Jeroen van Kwawegen JV1010
+
+Printed name and bar number
+
+Bernstein Litowitz Berger & Grossmann LLP 1251 Avenue of the Americas New York, NY 10020
+
+Address
+
+jeroen@blbglaw.com
+
+E-mail address
+
+(212) 554-1400
+
+Telephone number
+
+(212) 554-1444
+
+FAX number
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diff --git a/marker2/court-pension-v-dimon/EFTA02823151/EFTA02823151.md b/marker2/court-pension-v-dimon/EFTA02823151/EFTA02823151.md
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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+CITY OF MIAMI GENERAL EMPLOYEES & SANITATION EMPLOYEES RETIREMENT TRUST
+
+and
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND,
+
+Plaintiffs,
+
+v.
+
+JAMES DIMON, STEPHEN B. MI, TODD A. COMBS, JAMES S. CROWN, TIMOTHY P. FLYNN, MELLODY HOBSON, JOHN W. KESSLER, PHEBE N. NOVAKOVIC, and JAMES E. STALEY,
+
+Defendants,
+
+and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+Case Number: 1:23-cv-03903 (JSR)
+
+## REPLY IN SUPPORT OF DEFENDANTS' MOTION TO DISMISS THE AMENDED STOCKHOLDER DERIVATIVE COMPLAINT
+
+### TABLE OF CONTENTS
+
+| I.         | The Complaint Fails Adequately to Plead Demand Futility................................................1 |
+|------------|----------------------------------------------------------------------------------------------------------|
+| A.         | Directors Who Joined the Board After Epstein Was Terminated as a Client                                  |
+|            | Do Not Face a Substantial Likelihood of Liability ..2                                                    |
+| B.         | Plaintiffs Fail to Plead That the Remaining Demand Board Directors                                       |
+|            | (M, Crown, Dimon, and Flynn) Face a Substantial Likelihood of                                            |
+| C.         | Plaintiffs Fail to Plead Facts Sufficient to Show That Any Demand Board                                  |
+|            | Director "Lacks Independence." 6                                                                         |
+| II.        | The Complaint Fails to State a Claim Against Any Defendant 8                                             |
+| CONCLUSION | 10                                                                                                       |
+
+#### TABLE OF AUTHORITIES
+
+| Cases In re Am. Int'l Grp., Inc. Deriv. Litig.,                                                               | Page(s) |
+|---------------------------------------------------------------------------------------------------------------|---------|
+| 700 F. Supp. 2d. 419 (S.D.N.Y. 2010), afd, 415 F. App'x 285 (2d Cir. 2011) Cantor Fitzgerald, L.P. v. Cantor, | 7       |
+| 724 A.2d 571 (Del. Ch. 1998)                                                                                  | 10      |
+| In re Citigroup, Inc. S'holder Der& Litig.,                                                                   |         |
+| 964 A.2d 106 (Del. Ch. 2009) Desimone v. Barrows,                                                             | 2       |
+| 924 A.2d 908, 940 (Del. Ch. 2007)                                                                             | 5       |
+| 2016 WL 301245 (Del. Ch. Jan. 25, 2016) Horman v. Abney,                                                      | 7       |
+| No. CV 12290-VCS, 2017 WL 242571 (Del. Ch. Jan. 19, 2017) Kosovich v. Metro Homes, LLC,                       | 9       |
+| No. 09 Civ. 6992 (JSR), 2009 WL 5171737 (S.D.N.Y. Dec. 30, 2009) Latin v. Wise,                               | 3       |
+| No. Civ.A. 1280-N, 2005 WL 3501709 (Del. Ch. Dec. 14, 2005) Marchand v. Barnhill,                             | 2       |
+| 212 A.3d 805 (Del. 2019)                                                                                      | 6       |
+| 2021 WL 4593777 (Del. Ch. Oct. 5, 2021) Mason-Mahon v. Flint,                                                 | 4, 5    |
+| 166 A.D.3d 754 (2d Dept 2018) In re McDonald's Corp. S'holder Der& Litig.,                                    | 6       |
+| 289 A.3d 343 (Del. Ch. 2023)                                                                                  | 9       |
+| 2016 WL 4076369 (Del. Ch. Aug. 1, 2016)                                                                       | 4       |
+| In re MetLife Inc. Der& Litig.,                                                                               |         |
+| No. CV 2019-0452-SO, 2020 WL 4746635 (Del. Ch. Aug. 17, 2020)                                                 | 2       |
+
+In re NutriSystem, Inc. Deriv. Litig., 666 F. Supp. 2d 501 (E.D. Pa. 2009) X
+
+(V.v. M No. 3468-VCP, 2008 WL 5053448 (Del. Ch. Nov. 26, 2008) 7
+
+Oklahoma Firefighters Pension & Ret. Sys. v. Corbat, No. CV 12151-VCG, 2017 WL 6452240 (Del. Ch. Dec. 18, 2017) 2
+
+on Behalf of Esperion Therapeutics, Inc. v. Mayleben, No. CV 12985-VCS, 2020 WL 748023 (Del. Ch. Feb. 13, 2020), asond sub non:. v. Mayleben, 241 A.3d 218 (Del. 2020) 7
+
+In re Oxford Health Plans, Inc., 192 F.R.D. 111 (S.D.N.Y. 2000) 6
+
+In re Ply Gem Indus., Inc. S'holders Litig., No. CIV. A. 15779-NC, 2001 WL 755133 (Del. Ch. Oct. 3, 2001), reh'g denied, 2001 WL 1192206 (Del. Ch. Oct. 3, 2001) 8
+
+Rahbari v. Oros, 732 F. Supp. 2d 367 (S.D.N.Y. 2010) 8
+
+In re Tesla Motors, Inc. S'holder Litig., Consol. C.A. No. 12711-VCS, 2018 WL 1560293 (Del. Ch. Mar. 28, 2018) 8
+
+Tri-State Pension Fund v. Zuckerberg, 262 A.3d 1034 (Del. 2021) 1, 2
+
+Westmoreland Cnty. Emp. Ret. Sys. v. Parkinson, 727 F.3d 719 (7th Cir. 2013) 4
+
+# Other Authorities
+
+Bank Secrecy Act/Anti-Money Laundering Examination Manual, Federal Financial Institutions Examination Council, at 67-68 (2006) 4
+
+Financial Crimes Enforcement Network, Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations (Jan. 19, 2021) 5
+
+Federal Rule of Evidence 23.1 1
+
+The Opposition alternates between criticizing the Board for being "ignorant to Epstein's crimes (or even the fact that Epstein was a client)," and speculating "one could have imagined...information...would have made its way to the Board" and "it is reasonably inferable" that Directors learned of purported failures to meet BSA obligations. Whatever theory Plaintiffs are advancing, however, the Opposition makes clear that Plaintiffs cannot identify any wellpleaded facts showing that the Director Defendants were actually aware of Epstein's illegal activity, purported failures to meet BSA obligations, or even that Epstein was a Bank client. Plaintiffs' rank speculation comes nowhere close to pleading that the Demand Board Directors face a substantial likelihood of liability or lack independence from another director who does requiring dismissal for failure to plead demand futility. Plaintiffs also fail to plead that any Defendant engaged in bad faith misconduct sufficient to state a breach of fiduciary duty claim. The Complaint should be dismissed with prejudice.
+
+# ARGUMENT'
+
+# I. The Complaint Fails Adequately to Plead Demand Futility.2
+
+In Opposition, Plaintiffs concede that demand would not be futile on four of the twelve members of the Demand Board (, Gorsky, Hobson, and Rometty). The Opposition also does nothing to remedy Plaintiffs' failure to sufficiently plead in their Complaint that six of the remaining eight members of the Demand Board were conflicted under the stringent demand futility standard. Specifically, Plaintiffs cannot show that six of the remaining Demand Board Directors
+
+Capitalized terms not otherwise defined have the meanings ascribed to them in Defendants' Memorandum of Law in Support of Defendants' Motion to Dismiss [Doc. 251 ("Mot.").
+
+<sup>2</sup> Plaintiffs' description of the Rule 23.1 pleading requirements understates the stringent standard. The Court is only required to accept as true the Complaint's "particularized and well-pleaded allegations." United Food & Com. Workers Union & Participating Food Indus. Emps.' Tri-State Pension Fund v. Zuckerberg, 262 A.3d 1034, 1048 (Del. 2021) ("Zuckerberg")
+
+either (1) "face a substantial likelihood of liability on any of the claims" or (2) "lack[] independence from someone" conflicted under (I). Zuckerberg, 262 A.3d at 1058.3
+
+## A. Directors Who Joined the Board After Epstein Was Terminated as a Client Do Not Face a Substantial Likelihood of Liability.
+
+Plaintiffs do not dispute that eight Demand Board Directors joined the Board following the termination of Epstein as a client (Mot. 11-12) and, as to five of these directors (, Gorsky, Hobson, Novakovic, and Rometty), Plaintiffs do not even attempt to assert a substantial likelihood of liability. Focusing on only three directors (Bammann, Combs, and Neal),4 Plaintiffs argue that they face a substantial likelihood of liability because of the 2014 Consent Order with the OCC and a deferred prosecution agreement ("DPA"), relating to Bernie Madoff. 5 In particular, Plaintiffs argue that it is "reasonably inferable" that, as a result of the government settlements, the thencurrent Board was told about "past suspicious activity concerning Epstein," and that "[i]t logically
+
+<sup>3</sup> As to Staley, unable to dispute that the claims have already been asserted, Plaintiffs complain that the Bank waited too long. Unsurprisingly, Plaintiffs cite no legal precedent in support of their argument, much less any legal basis for Plaintiffs' request for "a seat at the table" of any settlement discussions between JPMorgan and Staley (an impractical proposal that prioritizes the interests of two plaintiff shareholders). Opp. 22.
+
+<sup>4</sup> It is telling that Plaintiffs have not asserted claims against Bammann and Neal, which dramatically undermines any argument that these individuals face a substantial risk of personal liability. Laties v. Wise, No. Civ.A. 1280-N, 2005 WL 3501709, at \*2 (Del. Ch. Dec. 14, 2005) (granting motion to dismiss and finding no substantial likelihood of liability where complaint did not assert "conduct for which the directors may be liable"). As to Combs, he joined the Board in 2016, making the 2014 Consent Order and DPA of no relevance to him.
+
+<sup>5</sup> Because the government settlements arose from Madoff-related issues, they are insufficiently related to the underlying Epstein-related allegations to be relevant here. See, e.g., In re MetLife Inc. Deriv. Ling., No. CV 2019-0452-SG, 2020 WL 4746635, at \*15 (Del. Ch. Aug. 17, 2020) (failure to incorporate improved processes from government investigations and a regulatory settlement agreement across even 'analogous' lines of business" did not support inference of directors' bad faith); Oklahoma Firefighters Pension & Rel. Sys. v. Corbat, No. CV 12151-VCG, 2017 WL 6452240, at \*15 (Del. Ch. Dec. 18, 2017) (the corporate trauma in question "must be sufficiently similar to the misconduct implied by the 'red flags' such that the board's bad faith, 'conscious inaction' proximately caused that trauma" (quoting Melbourne Mun. Firefighters' Pension Tr. Fund on Behalf of Qualcomm, Inc. v. 2016 WL 4076369, at \*8 (Del. Ch. Aug. I, 2016)); In re Citigroup, Inc. S'holder Daly. Ling., 964 A.2d 106, 129 (Del. Ch. 2009) (rejecting argument that "alleged prior, unrelated wrongdoing would make directors 'sensitive to similar circumstances").
+
+follows that it is reasonably inferable" that the Board also learned of the purported "failure to timely file Epstein-related SARs." Opp. 17. These allegations are not pleaded in the Complaint. See Kosovich v. Metro Homes, LLC, No. 09 Civ. 6992 (JSR), 2009 WL 5171737, at •5 n.6 (S.D.N.Y. Dec. 30, 2009) ("[I]t is axiomatic that the Complaint cannot be amended by the briefs in opposition to a motion to dismiss.") (quoting Supp. 222, 229 (S.D.N.Y. 1989)). v. Nat'l Prop. Analysts Partners, 719 F.
+
+Even assuming these new allegations were properly before the Court, they are wildly speculative. The provision of the Consent Order cited by Plaintiffs required an independent consultant to conduct a look-back review of "the quality of SARs filed [to] determine whether corrections or amendments are necessary to ensure that the suspicious activity identified was accurately reported." (Ex. 1 [Doc. 31-1], Art. VIII). Accepting as true Plaintiffs' assertion that JPMorgan "filed zero SARs related to Epstein" (Compl. ¶9 183, 26), a review of previous filings made to comply with BSA/AML obligations would identify nothing. And Plaintiffs do not plead that the consultants identified any failures related to AML compliance related to Epstein—much less that any were elevated to the Board. Likewise, Plaintiffs cite a Consent Order provision requiring review of transaction activity "covering non-bank financial institutions" (id., Art. IX), but do not explain how this review would even hypothetically implicate Epstein's accounts—much less that any such review was elevated to the Board.
+
+But even accepting the string of unpleaded hypotheticals positing that the Consent Order would have caused information to be elevated to the Board, Plaintiffs' argument makes no sense. The 2014 DPA and Consent Order occurred after the Bank had terminated Epstein as a client in 2013. Since Epstein had already been terminated as a client, such hypothetical after-the-fact knowledge by the then-current 2014 Board still would not establish a breach of fiduciary duty by
+
+Directors for activities relating to Epstein's accounts that had already been closed.6 And, as Plaintiffs do not dispute, JPMorgan enhanced its BSA/AML policies and procedures as part of the government settlements, so the then-current Board would have had every reason to believe that any compliance weaknesses had been addressed—and Plaintiffs do not allege that the Board subsequently learned of any inadequacies in those systems.
+
+Certainly, Plaintiffs cannot plead that compliance systems were not in place? and the Bank's commitment to enhance its BSA/AML procedures would have provided further comfort to the Board that appropriate measures were in place as of 2014.8
+
+<sup>6</sup> Plaintiffs cite Westmoreland Cnty. Emp. Ret. Sys. v. Parkinson, which is inapposite. 727 F.3d 719 (7th Cir. 2013). In that case, Plaintiffs alleged that "[d]espite repeated warnings from the FDA that [the Company's] remedial efforts were insufficient—warnings that were directly communicated to [the] CEO [] and passed along to the board of directors—the board took no action to ensure the company's timely compliance with the law." Id. at 726. Unlike here, "the complaint allege[d] particularized facts (e.g., meeting dates and minutes) indicating that the directors were intimately involved in overseeing the remedial effort." Id. at 728 The Complaint here contains no such allegations—much less any allegations before Epstein's accounts were terminated. Plaintiffs also quote =, 2016 WL 4076369 at \*12, for the proposition that "when board learns of illegality, it has an 'immediate duty' to alter the company's 'business practices."' Opp. 16. The "illegality" referenced actually consisted of pleading guilty to criminal charges including a "felony count for willful violation of mandatory safety standards." , 2016 WL 4076369 at \*12. In either case, the Complaint here does not plead that the Board actually learned of any Epsteinrelated illegality, much less before the Epstein accounts were terminated, and still took no action to alter JPMorgan's business practices.
+
+<sup>7</sup> The Comptroller's Findings in the 2013 Consent Order, Ex. 1 [Doc. 31-1], Art. I, and 2014 Consent Order, Ex. 2 [Doc. 31-2], Art. I, acknowledge the existence of various compliance programs, and the mere finding of deficiencies in those programs does not satisfy Zuckerberg. See Firemen's Ret. Sys. of St. Louis a rel. Marriott Intl, Inc. v. Sorenson, 2021 WL 4593777, at \*16 (Del. Ch. Oct. 5, 2021) ("Even if the gaps in [the Company's] data security evidenced the sort of compliance failure that could support a viable claim under the second prong of Caremark, the Complaint lacks particularized allegations that the Board consciously overlooked or failed to address them.").
+
+<sup>8</sup> Plaintiffs cite the FFIEC Manual to argue that "federal regulations require AML risk oversight at the board level" (Opp. 4-5), but the FFIEC Manual, which provides guidance to bank examiners, does not suggest customer-specific updates to the Board are required—to the contrary, it says that "banks may opt to provide [the board] summaries, tables of SARs filed for specific violation types, or other forms of notification." Bank Secrecy Act/Anti-Money Laundering Examination Manual, Federal Financial Institutions Examination Council, at 67-68 (2006), https://www.ffiec.gov/pdffbsa\_aml\_examination\_manua12006.pdf.
+
+#### B. Plaintiffs Fail to Plead That the Remaining Demand Board Directors (=, Crown, Dimon, and Flynn) Face a Substantial Likelihood of Liability.
+
+While not necessary to reach, Plaintiffs also cannot establish a substantial likelihood of personal liability for the Demand Board Directors who served while Epstein was a client Crown, Dimon, and Flynn). Plaintiffs concede that =, Crown, and Flynn were "ignorant to Epstein's crimes (or even the fact that Epstein was a client)." Opp. 5. Plaintiffs instead allege lower-level employee knowledge (Opp. 12-13), and muse that loine would have imagined that at least some of that information ... would have made its way to the Board." Id. at 13.
+
+Such imaginings, however, do not plead a Caremark claim, which requires both director knowledge of the misconduct and a conscious failure to act upon that knowledge. Firemen's Ret. Sys. ofSt. Louis v. Sorenson, No. CV 2019-0965-LWW, 2021 WL 4593777, at \*13 (Del. Ch. Oct. 5, 2021) (plaintiff must allege directors "knew about 'red flags' alerting them to corporate misconduct and consciously failed to act after learning about evidence of illegality") (internal quotation marks omitted). The cases cited by Plaintiff acknowledge that the law requires directors to ensure management has implemented procedures to monitor risks, and keep the Board informed about risk management. See Opp. 12, 14. These cases do not in any way support Plaintiffs' contention that Board knowledge can be inferred from lower-level employees.
+
+Plaintiffs make the leap that simply because Epstein was a client, the Board must not have installed adequate BSA/AML controls. This is not the law. Even if a violation of law had occurred (which Plaintiffs have not established),9 that would not establish either deficient controls or a failure of oversight. Desimone v. Barrows, 924 A.2d 908, 940 (Del. Ch. 2007) ("Delaware courts
+
+<sup>9</sup> Plaintiffs do not cite any legal requirement that a bank must exit a client relationship where the bank files a SAR relating to that client. See Financial Crimes Enforcement Network, Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations (Jan. 19, 2021) ("There is no BSA regulatory requirement to terminate a customer relationship after the filing of a SAR or any number of SARs"), httns://www. fincen.gov/sites/default/files/2021-01/Joint%20SAR%20FAQs%20Final%20508.pdf.
+
+routinely reject the conclusory allegation that because illegal behavior occurred, internal controls must have been deficient, and the board must have known so.").
+
+The cases cited by Plaintiffs are not contrary. In Mason-Mahon v. Flint, a case applying New York rather than Delaware law, Plaintiffs alleged that the "board had specific information or reason to inform itself regarding HSBC Bank's payments of alleged penalties." 166 A.D.3d 754, 758 (2d Dept 2018). Plaintiffs admit that there is no such allegation here. Plaintiffs also cite Marchand v. Barnhill, but the "tough" Caremark standard was met in Marchand only because "no system of board-level compliance monitoring" existed and because the board had received many "red flag" reports regarding food safety issues. 212 A.3d 805, 822 (Del. 2019). As Plaintiffs concede, they must "plead an inference that a board has undertaken no efforts to make sure it is informed of a compliance issue" in order to meet the "good faith effort that Caremark requires." Id.1° The Complaint, however, is replete with allegations of a robust and functioning BSA/AML compliance program. See, e.g., Compl. ¶¶ 18-21, 51, 129-30, 134. As such, Plaintiffs have failed to credibly allege a Caremark claim and therefore have failed to demonstrate a substantial likelihood of liability even for those members of the Demand Board who were on the Board while Epstein was a client of the Bank.
+
+# C. Plaintiffs Fail to Plead Facts Sufficient to Show That Any Demand Board Director "Lacks Independence."
+
+Plaintiffs' arguments that Novakovic and Bammann lack independence also fail.
+
+Novakovic. Although Plaintiffs now concede that the claims against Novakovic should be dismissed (Opp. 17 n.7), Plaintiffs argue that Novakovic lacks independence from deceased
+
+<sup>10</sup> In re Oxford Health Plans, Inc. is similarly unavailing and irrelevant to the conduct alleged in the Complaint. 192 F.R.D. III, 144 (S.D.N.Y. 2000). There, demand was excused because plaintiffs alleged that demand board directors had traded on inside information, purposely misled shareholders, and allowed the company to engage in wholesale improper billing practices and violate numerous insurance regulations. Id.
+
+director Crown, who purportedly faced a substantial likelihood of liability." For the reasons stated infra, former director Crown did not face a substantial risk of liability. Further, Plaintiffs allege only that Crown, who was already deceased at the time this allegation was first made, "likely had the influence to fire Novakovic." Compl. y 195.12 This speculation falls far short of overcoming the strong presumption that directors operate independently and faithfully in their fiduciary duties. See In re Am. Int 7 Grp., Inc. Deriv. Litig., 700 F. Supp. 2d. 419, 432 (S.D.N.Y. 2010), affd, 415 F. App'x 285 (2d Cir. 2011). Plaintiffs' reliance on In re Ezcorp Inc. Consulting Agreement Der& Litig. is unavailing. 2016 WL 301245 (Del. Ch. Jan. 25, 2016). There, the director whose independence was challenged was employed by an entity with common ownership as the company whose board was considering the litigation demand. Id. at \*36. In addition to common ownership, the two entities were partners in a joint venture, and the company had disclosed that the director was not independent for the purposes of the NASDAQ listing standards. Id.
+
+Bammann. As to Non-Defendant Bammann, Plaintiffs claim she suffers a "sense of owingness to Dimon." Opp. 20. As an initial matter, for the reasons stated infra and supra, Dimon does not face a substantial risk of liability. Regardless, Plaintiffs' broad and non-particularized allegations of Bammann's non-independence are belied by the cases cited in Plaintiffs' own brief—neither of which arises in the context of assessing independence for the purposes of demand futility. See, e.g., Off v. No. 3468-VCP, 2008 WL 5053448, at \*I I (Del. Ch. Nov. 26, 2008) (non-independent director was the of business school to which interested party had donated
+
+<sup>11</sup>Plaintiffs have not contested Defendants' argument that former Director Crown is independent (Mot. 17-18) and therefore Plaintiffs have conceded his independence. See on Behalf of Esperion Therapeutics, Inc. v. Mayleben, No. CV 12985-VCS, 2020 WL 748023, at \*10 n.126 (Del. Ch. Feb. 13, 2020) (holding that three directors' independence was established because Plaintiff did not challenge these directors' independence in its answering brief), afj'd sub nom. v. Mayleben, 241 A.3d 218 (Del. 2020), as corrected (Nov. 18, 2020).
+
+<sup>12</sup> Plaintiffs now allege that Novakovic lacks independence from Crown's estate—but Plaintiffs have not sought to substitute the estate as a defendant in this action.
+
+\$100 million resulting in naming of school after interested party); In re Ply Gem Indus., Inc. S'holders Litig., No. CIV. A. 15779-NC, 2001 WL 755133, at \*9 (Del. Ch. Oct. 3, 2001) (nonindependent director's law firm had received \$1 million in legal fees), reh'g denied, 2001 WL 1192206 (Del. Ch. Oct. 3, 2001). Plaintiffs' argument that Bammann owes some of her professional success to Dimon simply because she worked with him at Bank One Corporation and then JPMorgan in the early 2000s (Compl. ¶ 193) dates back 20 years ago and is plainly insufficient for a finding that Bammann is presently conflicted. See Rahbari v. Oros, 732 F. Supp. 2d 367, 388 n.24 (S.D.N.Y. 2010) ("[M]ere personal or business relationships will not raise a reasonable inference that a director cannot consider demand, absent specific factual allegations to support such a conclusion."); In re NutriSystem, Inc. Deriv. Litig., 666 F. Supp. 2d 501, 515 (ED. Pa. 2009) ("[M]erely being employed by a corporation is not, by itself, sufficient to create a reasonable doubt as to the independence of a director."). Plaintiffs' assertion that Dimon is a "giant in the industry" (Opp. 20) such that that no board member is truly independent is unsupported by law.'3
+
+# II. The Complaint Fails to State a Claim Against Any Defendant.
+
+Demand Board Directors. Plaintiffs admit that their claims against Novakovic and Hobson must be dismissed.14 As to the other Demand Board Directors, for the same reasons Plaintiffs fail to plead a substantial risk of liability, see supra Section I.B., Plaintiffs also fail to state a claim.
+
+Kessler. Plaintiffs' one-sentence response (Opp. 22-23) fails to engage with Defendants'
+
+<sup>13</sup> Plaintiffs' citation to In re Tesla Motors, Inc. S'holder Litig., Consol. C.A. No. 12711—VCS, 2018 WL 1560293 (Del. Ch. Mar. 28, 2018), does not support this proposition. The court acknowledged Musk's "extraordinary influence within the Company generally," id. at \*16, but relied upon specific allegations that Musk had a history of ousting senior management when displeased, id. at \*15; there was no special committee process for the particular transaction at issue, id. at \*17; Musk did not recuse himself from and instead led the board's discussions of the transaction, id. at •16; and the fairness opinion process was possibly flawed, id. at \*9-10.
+
+<sup>14</sup> Plaintiffs expressly abandoned their claims against Defendants Hobson and Novakovic (Opp. 17 n.7), requiring their dismissal.
+
+showing that Plaintiffs failed to plead a Caremark claim against Kessler (Mot. 19-20), and effectively concedes dismissal is required.
+
+Dimon. Plaintiffs' discussion concerning Dimon (Opp. at 9-11) is remarkable only for what it omits. Plaintiffs plead Dimon's purported knowledge of alleged BSA/AML noncompliance as the basis for their claim against him (Opp. 9), but the Opposition does not cite a single allegation from the Complaint that Dimon was aware of any BSA/AML noncompliance with respect to Epstein accounts, because there are none. The Opposition also fails to address the point (Mot. 21) that the Complaint nowhere alleges that Dimon had any role in particular SARs filings. Finally, the Opposition does not address bad faith as to Dimon, much less explain why he plausibly would receive and ignore red flags concerning violations of BSA/AML law. See Horman v. Abney, No. CV 12290-VCS, 2017 WL 242571, at \*9 (Del. Ch. Jan. 19, 2017) (no oversight claim without bad faith). These shortcomings are fatal to the claim against Dimon because Caremark requires Plaintiffs to plead that the defendant was responsible for addressing the supposed red flags, yet in bad faith did nothing. See In re McDonald's Corp. S'holder Deriv. Litig., 289 A.3d 343, 350 (Del. Ch. 2023). The Complaint does not do so.15
+
+Unable to muster the allegations required to state a Caremark claim against Dimon, the Opposition seeks to distract with tenuous, irrelevant assertions that Dimon supposedly interacted with or learned something about Epstein. Id. at 9-11. These allegations are irrelevant because they do not assert instances of BSA/AML noncompliance, much less assert knowledge by Dimon of such noncompliance. The same is true of the Opposition's reference (at 2, 10) of Staley's
+
+<sup>15</sup> Plaintiffs also try to avoid dismissal by imagining that Defendants in their Motion to Dismiss prematurely demand "proof' of claims against Dimon. Opp. 10. Not so. Defendants' Brief is carefully cabined to the allegations of the Complaint and does not discuss "proof"; rather, the problem is that the Complaint lacks "facts supporting an inference that the fiduciary knew of evidence of corporate misconduct," "consciously failed to take action in response," and acted in bad faith in doing so. In re McDonald's Corp. S'holder Der& Litig., 289 A.3d at 376.
+
+alleged conversations with Dimon, which Plaintiffs conspicuously did not plead anywhere in the Complaint and, in any event, even the Opposition makes no claim that any such conversation concerned any alleged BSA/AML noncompliance, the theory undergirding Plaintiffs' claim. Finally, although it would be insufficient to state a claim, the allegations also do not show that Dimon was aware that Epstein was a bad actor or even a client of JPMorgan.16
+
+Uniust Enrichment Claim. Plaintiffs do not address or dispute Defendants' showing that Plaintiffs have failed to allege an "enrichment" or "impoverishment," as required under Delaware law to state a claim for unjust enrichment. See Cantor Fitzgerald, L.P. v. Cantor, 724 A.2d 571, 585 (Del. Ch. 1998); Mot. 24. This concession requires dismissal. Plaintiffs also acknowledge that their unjust enrichment claim is duplicative of breach of fiduciary duty (Opp. 23), and thus is subject to dismissal for the reasons set forth infra at Section II.
+
+# CONCLUSION
+
+For these reasons, and those set forth in Defendants' opening brief, the Court should dismiss the Complaint with prejudice.
+
+<sup>16</sup> Half of the allegations in Plaintiffs' list merely assert that employees other than Dimon had concerns about Epstein and discussed those concerns amongst themselves. They do not mention Dimon at all and cannot possibly support a claim against him. Opp. 9-11. One listed allegation asserts that the CEO of JPM's Asset and Wealth Management business knew about Epstein's crimes in 2006 and that this individual reported to Dimon. Id. at 9. But this is also inadequate because there is no allegation the individual discussed with Dimon what the individual allegedly knew, and it is preposterous to posit that Dimon automatically knew everything that any of the people reporting to him knew. Mother allegation (addressed Mot. at 21-22) asserts that an unidentified employee once wrote an email vaguely referencing a "Dimon review" with respect to Mr. Epstein. But Plaintiffs do not allege that this review even occurred, much less allege what it concerned or what Dimon supposedly learned. Finally, Plaintiffs assert the facially irrelevant allegation that Epstein helped Staley schedule meetings intended for Dimon to attend. Opp. 9-10. But the Complaint doesn't allege that Dimon was aware of Epstein's involvement, that the meetings even happened, or that Epstein was discussed at all at the meetings, much less his criminal conduct.
+
+Dated: July 27, 2023
+
+## WILMER CUTLER PICKERING HALE AND DORR LLP
+
+By: /s/ Timothy Perla Timothy Perla 60 State Street Boston, 02109 (t) (617) 526-6000 (f) (617) 526-5000 timothy.perla@wilmerhale.com
+
+Noah A. Levine 7 World Trade Center 250 Greenwich Street New York, NY 10007 (t) (212) 230-8800 (f) (212) 230-8888 noah.levine@wilmerhale.com
+
+## PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
+
+By: /s/Audra J. Solowav Audra J. Soloway Jessica S. Carey Jacobus J. Schutte 1285 Avenue of the Americas New York, NY 10019-6064 Phone: (212) 373-3000 Fax: (212) 757-3990 asoloway@paulweiss.com
+
+Counsel for Director Defendants Stephen B. , Todd A. Combs, James S. Crown, Timothy P. Flynn, Mellody Hobson, John W. Kessler, and Phebe N. Novakovic
+
+Counsel for Defendants JPMorgan Chase & Co. and James Dimon
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02823166/EFTA02823166.md b/marker2/court-pension-v-dimon/EFTA02823166/EFTA02823166.md
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@@ -0,0 +1,133 @@
+#### IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JPMORGAN CHASE & CO. DERIVATIVE LITIGATION
+
+=Case No. 1:23-cv-03903-JSR
+
+DERIVATIVE ACTION
+
+### DEFENDANT JAMES E. STALEY'S REPLY MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS COMPLAINT
+
+#### TABLE OF CONTENTS
+
+| I.         | The Bank's Existing Lawsuit Against Mr. Staley Quashes this Derivative Suit | 1 |
+|------------|-----------------------------------------------------------------------------|---|
+| II.        | The Claims Against Mr. Staley Specifically Are Defective                    | 4 |
+|            | A. Plaintiffs Fail To State a Breach-of-Fiduciary Duty Claim Against        |   |
+|            | Mr. Staley                                                                  | 4 |
+|            | B. Plaintiffs Fail To State an Unjust Enrichment Claim Against Mr. Staley   | 6 |
+| III.       | The Claims Against Mr. Staley Are Time-Barred                               | 6 |
+| CONCLUSION |                                                                             | 9 |
+
+#### TABLE OF AUTHORITIES
+
+|                                               | CASES                                                                                                  | Page(s) |
+|-----------------------------------------------|--------------------------------------------------------------------------------------------------------|---------|
+| Am.-Exch., LLC v. Mopex, Inc.,                | 215 F.R.D. 87 (S.D.N.Y. 2002)                                                                          | 3       |
+| AT & T Corp. v. Syniverse Techs., Inc.,       | 2014 WL 4412392 (S.D.N.Y. Sept. 8, 2014)                                                               | 6       |
+| In re Coca-Cola Enters., Inc., 2007           | WL 3122370 (Del. Ch. Oct. 17, 2007)                                                                    | 8       |
+| Curtis v. Citibank, N.A.,                     | 226 F.3d 133 (2d Cir. 2000)                                                                            | 3       |
+| De Sole v. Knoedler Gallery, LLC,             | 137 F. Supp. 3d 387 (S.D.N.Y. 2015)                                                                    | 7       |
+| In re Witter P 'ship Litig.,                  | 1998 WL 442456 (Del. Ch. July 17, 1998)                                                                | 8       |
+| In re Delta & Pine Land Co. S'holders Litig., | 2000 WL 875421 (Del. Ch. June 21, 2000)                                                                | 2       |
+| Diffley v. Allied-Signal, Inc.,               | 921 F.2d 421 (2d Cir. 1990)                                                                            | 7       |
+| In re McDonald's,                             | 289 Aid 343 (Del. Ch. 2023)                                                                            | 4, 5    |
+| Meyers v. Keeler,                             | 414 F. Supp. 935 (W.D. Okla. 1976)                                                                     | 2       |
+| Nemec v. Shrader,                             | 991 A.2d 1120 (Del. 2010) (en banc)                                                                    | 6       |
+| Ret. Sys. v. Carlson,                         | 2010 WL 2376890 (Del. Ch. June 7, 2010)                                                                | 6       |
+| Huck ex reL Sea Air Shuttle Corp. v. Dawson,  | 106 F.3d 45 (3d Cir. 1997)                                                                             | 3       |
+| Silvemveig v. Unocal Corp.,                   | 1989 WL 3231 (Del. Ch. Jan. 19, 1989)                                                                  | 2, 3    |
+| Stafford v. Intl Harvester Co.,               | 668 F.2d 142 (2d Cir. 1981)                                                                            | 7       |
+| Steinberg v. Dimon,                           | 2014 WL 3512848 (S.D.N.Y. July 16, 2014)                                                               | 6       |
+| Tilden v. Cunningham,                         | 2018 WL 5307706 (Del. Ch. Oct. 26, 2018)                                                               | 8       |
+| In re Tyson Foods, Inc.,                      | 919 A.2d 563 (Del. Ch. 2007) U.S. Bank Nat'l Ass'n as Tr. to Bank of Am., N.A. v. KeyBank, Nall Ass'n, | 7, 8    |
+| 2023 WL 2745210 (S.D.N.Y. Mar. 31, 2023)      |                                                                                                        | 7       |
+| Willensky v. Lederman,                        | 2015 WL 327843 (S.D.N.Y. Jan. 23, 2015)                                                                | 7       |
+
+Plaintiffs' Opposition asserts that it simply does not matter that JPMorgan has already sued Defendant Jes Staley on the very same claims, and for the very same acts, that are at issue in this derivative action. Of course it does: That the bank is already suing Mr. Staley shows that there is no need for Plaintiffs to do so on its behalf, nor any reason to excuse Plaintiffs' failure to petition the board before filing suit. Indeed, as to both demand futility and the rule against claim splitting, Plaintiffs' only response is that they can pursue the bank's interests better than JPMorgan's board. This is a baseless argument, as there is no legal doctrine that permits shareholders to usurp the board's prerogative, and disregard the rules against duplicative litigation, simply on the basis of second-guessing litigation management.
+
+As to the merits of their individual claims, moreover, Plaintiffs fare no better. They suggest that they can state a Caremark claim against Mr. Staley based on his alleged knowledge of Jeffrey Epstein's sexual misconduct, as though that somehow equates to knowledge of failed oversight procedures within JPMorgan. It does not. And on the statute of limitations, Plaintiffs rest the survival of their claims entirely on the exceedingly narrow doctrine of equitable tolling (which they did not plead) under Delaware law (which does not apply here). Coupled with Plaintiffs' inability to meet their burden to show demand futility, Plaintiffs' Opposition does nothing to forestall dismissal of the two claims against Mr. Staley (Counts II and III). The Court should therefore grant Mr. Staley's Motion to Dismiss.
+
+# I. The Bank's Existing Lawsuit Against Mr. Staley Quashes this Derivative Suit.
+
+The shareholder Plaintiffs do not dispute that nominal defendant JPMorgan—on whose behalf they purport to act—is already suing Jes Staley on the very same claims and theories that they seek to vindicate in this derivative action. See Third-Party Compls., Doe v. JPMorgan, 1:22 cv-10019-JSR, ECF No. 59; USV/ v. JPMorgan, 1:22-cv-10904-JSR, ECF No. 130. This undisputed fact presents two fatal obstacles to Plaintiffs' ability to proceed. Plaintiff.? Opposition does not seriously grapple with, much less rebut, either one.
+
+The first obstacle is, of course, Plaintiff? need to show demand futility. Having declined to petition JPMorgan's board of directors to bring their contemplated claims against Mr. Staley, Plaintiffs must show that doing so would have been a fool's errand because the board would not sue Mr. Staley on its own because of the legal risk to the board members. But the fact that the very same board has already taken exactly that action—seeking to hold Mr. Staley liable for, among other things, the full \$290 million settlement with the Jane Doe class—is ipso facto fatal to Plaintiff? theory of futility. See, e.g., In re Delta & Pine Land Co. S'holders Litig., 2000 WL 875421, at •6 (Del. Ch. June 21, 2000) ("[T]he existence of a board-initiated action conclusively defeats any claim that demand would have been futile." (internal citation omitted)).'
+
+Plaintiffs offer no substantive response to this point, and instead merely disparage JPMorgan's third-party actions as "belated and reactive," suggesting that they were intended solely to "deflect blame" from the bank, and thus that the bank might settle them "at a non-maximizing price." Opp'n at 21-22. But Plaintiffs cite no authority suggesting that a court should secondguess board members' motives even after they decide to pursue the claims that shareholders said they would not. Quite to the contrary, Delaware law suggests the opposite:
+
+> [T]he existence of [a board-initiated suit] conclusively defeats any claim that demand would have been futile. Indeed, there is something to be said for the idea that this Court should inquire no further if it finds that the corporate directors are litigating the same claims advanced in the derivative action.
+
+The Delta & Pine decision was no outlier. See, e.g., Silvernveig v. Unocal Corp., 1989 WL 3231, at \*4 (Del. Ch. Jan. 19, 1989), aff'd, 561 A.2d 993 (1989); Meyers v. Keeler, 414 F. Supp. 935, 939 (W.D. Okla. 1976).
+
+Silvetzweig, 1989 WL 3231, at •4. Simply put, the demand-futility doctrine is intended to address circumstances in which a supposedly conflicted board would refuse to pursue valid claims. It is not intended to allow shareholders to commandeer and micromanage litigation already underway. In all events, JPMorgan impleaded Mr. Staley less than four months after it was sued, and there can be no doubt that it has vigorously pursued claims against him ever since.2
+
+The second obstacle arises under the rule against claim splitting, i.e., the principle that a plaintiff "must bring in one action all legal theories arising out of the same transaction." Ant. Exch., LLC v. Mopex, Inc., 215 F.R.D. 87, 91 (S.D.N.Y. 2002); accord Curtis v. Citibank, N.A., 226 F.3d 133, 138-39 (2d Cir. 2000). This rule applies here because the very nature of a derivative action is that the plaintiff seeks to vindicate the claims of someone else—in this case, JPMorgan, which is already pursuing the same claims against Mr. Staley in this Court. See Huck ex ref. Sea Air Shuttle Corp. v. Dawson, 106 F.3d 45, 50-51 (3d Cir. 1997) (derivative action precluded by prior lawsuit based on similar claims).
+
+Plaintiffs' response on this point mirrors their response on demand futility, as they argue that the rule against claim-splitting is "discretionary," and that the Court should decline to apply it here because "the Company cannot be trusted to maximize the value of the claims against Staley." Opp'n at 25. This is a preposterous assertion: as noted above, no serious observer of the bank's lawsuit against Mr. Staley would describe it as anything less than hard fought on both sides. Moreover, the rule against claim-splitting is a well-developed concept, with multiple precedential factors to guide judges when applying it. See Curtis, 226 F.3d at 13841. Nowhere among those
+
+<sup>2</sup> Regarding demand futility more generally, Plaintiffs' attempts to rewrite their complaint through briefing is as ineffective as it is improper. Mr. Staley refrains from belaboring the diapositive arguments of his codefendants and instead adopts and incorporates by reference their Reply Brief. See ECF No. 34.
+
+factors is the notion that duplicative litigation should be tolerated simply because the driver of a later-filed action questions the bona fides of an earlier one. This Court should not be the first to recognize such a subjective and groundless principle.
+
+### II. The Claims Against Mr. Staley Specifically Are Defective.
+
+Plaintiffs' claims against Mr. Staley are substantively deficient even if one overlooks the claim-killing fact of the preexisting JPMorgan lawsuit. Plaintiffs' Opposition attempts to defend these claims on the merits, but fails completely.
+
+# A. Plaintiffs Fail To State a Breach-of-Fiduciary Duty Claim Against Mr. Staley.
+
+Count II purports to state a Caremark claim, alleging breach of fiduciary duty based on a breakdown of operating controls and corporate compliance functions at JPMorgan. This claim cannot proceed against Mr. Staley because the Complaint is devoid of any allegation that Mr. Staley—who was never a director, merely an officer—ever had responsibility for the compliance and oversight functions where, according to Plaintiffs, JPMorgan fell short.3 This is a fatal deficiency because Caremark liability attaches to a corporate officer only when the officer was responsible for receiving and addressing the supposed red flags of misconduct. In re McDonald's, 289 A.3d 343, 366 (Del. Ch. 2023) (officer's duty "to identify red flags, report upward, and address them if they fall within the officer's area of responsibility").
+
+Plaintiffs do not dispute Mr. Staley's point that he had no responsibility for the compliance functions. They instead assert that an exception to the "area of responsibility" principle exists and that a Caremark claim can still arise—where the defendant officer has actual knowledge of potential corporate wrongdoing, yet fails to act. Or, as the Plaintiffs put it—quoting from the
+
+<sup>3</sup> As the Complaint notes, AML and KYC compliance were managed by separate divisions at the bank, as was the filing of SARs. See Compl. ¶¶ 5, 147, 151, 181 (referencing, e.g., "compliance department," "risk management division," and "Global Corporate Security Division").
+
+McDonald's decision—"An officer who receives credible information that the corporation is violating the law cannot turn a blind eye and dismiss the issue as 'not in my area."' Opp'n at 23 (quoting id. at 370).
+
+The problem with Plaintiffs' reliance on this principle is that their Complaint is, again, devoid of any allegation that Mr. Staley was ever made aware that "the corporation" was "violating the law," as the rule from McDonald's would require. 289 A.3d 369-70. Although the Complaint is replete with (baseless) allegations that Mr. Staley knew of Jeffrey Epstein's misdeeds,' the actions of a bank's client do not equate to actions of the bank, and only the latter will suffice to state a "Red-Flags" variant of a Caremark claim. And there is no allegation that Mr. Staley ever knew, for example, of JPMorgan's alleged failures to submit SARs about Epstein or of any of the other purported "red flags" indicating a breakdown in the bank's back-end compliance functions. Indeed, to judge from the Complaint, one could conclude only that Mr. Staley believed that the bank was actively addressing Epstein's suspicious transactions, as the Complaint references multiple discussions he supposedly had with the higher-ups at the bank who bore actual responsibility for compliance. E.g., Compl. ¶¶ 25, 135-37, 181. In other words, regardless of whatever Mr. Staley might have known about Epstein's personal life, Plaintiffs' Complaint presents no basis to infer that he knew that the bank was falling short in its compliance and external reporting obligations over Epstein's accounts.
+
+Finally, Plaintiffs get no support from their afterthought citation to JPMorgan's allegation that "Staley's act of disloyalty . . . occurred in his primary area of responsibility." Opp'n at 24. Plaintiffs' own Complaint makes no such allegation, and, indeed, their Opposition otherwise
+
+<sup>4</sup> E.g., Opp'n at 24 (noting allegations (i) that Mr. Staley was "tasked with 'getting to know' Epstein," Compl. ¶ 15, and (ii) that another officer was supposed to tell Mr. Staley that the bank was "uncomfortable with Epstein," id. ¶ 18).
+
+denigrates JPMorgan's third-party claims as mere overhead cover to deflect blame away from the bank. See Opp'n at 21-22. But more importantly, an entirely conclusory and generalized allegation about Mr. Staley's purported "area of responsibility," devoid of specifics and factual support, is not a premise for Caremark liability based on compliance failures.
+
+### B. Plaintiffs Fail To State an Unjust Enrichment Claim Against Mr. Staley.
+
+Plaintiffs' unjust enrichment claim against Mr. Staley in Count III fails too. As noted in Mr. Staley's opening brief, the essence of the claim is breach of fiduciary duty, so it suffers from the same faults as Plaintiffs' Caremark claim against Mr. Staley in Count 11. See Monroe Cnty. Emps.' Ret. Sys. v. Carlson, 2010 WL 2376890, at \*2 (Del. Ch. June 7, 2010) (dismissing unjust enrichment claim based on deficient fiduciary duty claim).
+
+The unjust enrichment claim is also independently deficient. Such a claim requires, inter alia, (i) an express pleading of "the absence of a remedy provided by law," Nemec v. Shrader, 991 A.2d 1120, 1130 (Del. 2010) (en bane), and (ii) some form of alleged "enrichment" beyond the defendant's ordinary employment compensation, see Steinberg v. Dimon, 2014 WL 3512848, at \*4 (S.D.N.Y. July 16, 2014). Here, Plaintiffs' Complaint pleads neither prerequisite. Mr. Staley pointed out these failings in his opening brief (at 17-18), but Plaintiffs' Opposition fails to address them at all. The deficiency of Count III is thus conceded. See AT & T Corp. v. Syniverse Techs., Inc., 2014 WL 4412392, at \*7 (S.D.N.Y. Sept. 8, 2014) (unaddressed arguments are conceded).
+
+# HI. The Claims Against Mr. Staley Are Time-Barred.
+
+Plaintiffs' argument for the timeliness of their lawsuit rests on narrow grounds. See Opp'n 24-25. Plaintiffs do not dispute, for example, that Mr. Staley left JPMorgan in 2013—more than a decade ago—or that the applicable New York limitations periods had long since expired by the time they filed suit in May 2023. Nor do Plaintiffs so much as mention the tolling doctrines of fraudulent concealment or inherently unknowable injury. Id. Instead, Plaintiffs attempt to salvage
+
+their claim solely through "equitable tolling" under Delaware law—a doctrine that excuses untimeliness by a plaintiff who "reasonably relied" on a fiduciary and was otherwise ignorant of his claim. Id. (citing In re Tyson Foods, Inc., 919 A.2d 563, 585 (Del. Ch. 2007)). According to Plaintiffs, this doctrine should apply here, and for support they cite this Court's denial of the motions to dismiss in the Doe and USVI actions. This argument fails in every respect.
+
+First, Plaintiffs are simply wrong that Delaware law applies. In New York, forum law governs limitations. As the Second Circuit has observed:
+
+> Under New York law[,] the statute of limitations is considered procedural since it goes to the remedy, and New York will apply its own statute of limitations even though the injury which gave rise to the action occurs in another state.
+
+Stafford v. Intl Harvester Co., 668 F.2d 142, 147 (2d Cir. 1981). This is true even where Delaware law governs the merits under the internal affairs doctrine. Willensky v. Lederman, 2015 WL 327843, at \*5 n.8 (S.D.N.Y. Jan. 23, 2015) ("[N]o New York court has held that the internal affairs doctrine requires that it apply the statutes of limitations of a defendant corporation's home state.") (applying New York statute of limitations to shareholder derivative claims). And because New York's statutes of limitation apply, its law on tolling also applies,' and New York law notably does not recognize the fiduciary-duty-based equitable tolling theory advanced by Plaintiffs.'
+
+<sup>5</sup> U.S. Bank Nat? Ass 'n as Tr. to Bank of Am., N.A. v. KeyBank, Nat1 Ass n, 2023 WL 2745210, at \*12 (S.D.N.Y. Mar. 31, 2023) (explaining that New York law governs limitations and also "determines the related questions of what events serve to commence an action and to toll the statute of limitations") (quoting Diffley v. Allied-Signal, Inc., 921 F.2d 421, 423 (2d Cir. 1990)).
+
+<sup>6</sup> New York law's version of equitable tolling applies only where a plaintiff "establish[es] that subsequent and specific actions were taken by defendants, separate from those that provide the factual basis for the underlying cause of action, and that these subsequent actions by defendants somehow kept plaintiff from timely bringing suit." De Sole v. Knoedler Gallery, LLC, 137 F. Supp. 3d 387, 423 (S.D.N.Y. 2015) (cleaned up).
+
+Even if the Court were to apply Delaware tolling law as Plaintiffs urge, their argument would still fail. The background rule in Delaware is that "a claim accrues as soon as the wrongful act occurs," Tilden v. Cunningham, 2018 WL 5307706, at \*14 (Del. Ch. Oct. 26, 2018) (citation omitted), not "when the harmful effects of the act are felt—even if the plaintiff is unaware of the wrong," In re Coca-Cola Enters., Inc., 2007 WL 3122370, at '5 (Del. Ch. Oct. 17, 2007). Although Delaware law recognizes equitable tolling in certain circumstances, a plaintiff seeking refuge under that doctrine bears the burden to plead specific facts showing (i) that he delayed filing due to the fact that he "reasonably relied upon the competence and good faith of a fiduciary," and (ii) that he was "not on inquiry notice of [his] claims" during the claimed tolling period. /n re Tyson Foods, 919 A.2d at 585; In re Witter P 'ship Litig., 1998 WL 442456, at '6 (Del. Ch. July 17, 1998), aff'd, 725 A.2d 441 (Del. 1999).
+
+Plaintiffs, however, plead no such facts. Indeed, the section of their Opposition addressing this argument is devoid of even a single citation to the Complaint. Opp'n at 24-25. And even if Plaintiffs had actually tried to plead an equitable tolling theory under Delaware law in their Complaint—which they did not—they certainly could not premise it on a fiduciary relationship with Mr. Staley, as any such relationship ended when Mr. Staley left the bank in 2013, well outside any potentially applicable limitations period. Indeed, given that the Miami municipal employees' pension fund did not purchase JPMorgan common until December 2016 (Comp1.1 30), more than three years after Mr. Staley departed, it never had a fiduciary relationship with him, much less relied on that relationship.
+
+Finally, it matters not that the Court declined to dismiss JPMorgan's claims against Mr. Staley in the Doe and USVI actions. The Court's bottom-line rulings—based on different pleadings and arguments by the parties—do not control here. While it is true that Mr. Staley's
+
+motions contained statute-of-limitations arguments, Plaintiffs have offered no comparison of their complaint to the pleadings and allegations that the Court apparently found adequate in the USV/ and Doe suits. Nor did the bank defend untimeliness on equitable-tolling grounds, as Plaintiffs rely on here. And the Court has not yet issued any opinion(s) on the motions to dismiss in those cases, so Plaintiffs have no basis to contend that any rationale for the Court's rulings should also apply here.
+
+### CONCLUSION
+
+For the forgoing reasons, and the reasons set forth in Mr. Staley's opening brief (ECF No. 29), the Court should dismiss Counts II and III against Mr. Staley.
+
+Date: July 27, 2023 Respectfully submitted,
+
+/s/ John McNichols John McNichols & CONNOLLY LLP 680 Maine Avenue, S.W. Washington, DC 20024 Tel: (202) 434-5252 Fax: (202) 434-5029 jmcnichols@wc.com
+
+Counsel for Defendant James Edward Staley
\ No newline at end of file
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@@ -0,0 +1,47 @@
+## UNITED STATES DISTRICT COURT
+
+for the
+
+Southern District of New York
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND. et al. )
+
+Plaintiff )
+
+V. ) Case No. 23-cv-03903-JSR
+
+JAMES DIMON. et al. )
+
+Defendant )
+
+## APPEARANCE OF COUNSEL
+
+To: The clerk of court and all parties of record
+
+I am admitted or otherwise authorized to practice in this court, and I appear in this case as counsel for:
+
+City of Miami General Employees & Sanitation Employees Retirement Trust
+
+Date: 08/01/2023 /s/ Andrew Blumberg
+
+Attorney's signature
+
+Andrew Blumberg (NYS #5406160)
+
+Printed name and bar number
+
+Bernstein Litowitz Berger & Grossmann LLP 500 Delaware Avenue, Suite 901 Wilmington, DE 19801
+
+Address
+
+andrew.blumberg@blbglaw.com
+
+E-mail address
+
+(302) 364-3600
+
+Telephone ntunber
+
+(212) 554-1444
+
+FAX number
\ No newline at end of file
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+I, correct: J. Orrico, declare under penalty of perjury that the following is true and
+
+Case No. 1:23-CV-03903-(JSR)
+
+## DERIVATIVE ACTION
+
+## DECLARATION OF
+
+## J. ORRICO IN SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE
+
+I. I am a Partner/Principal with the law firm of Grant & Eisenhofer P.A. I am eligible to practice and a member in good standing in the State of New York and in the State of Connecticut. Certificates of Good Standing are appended hereto. I submit this declaration in support of my motion for admission to practice pro hac vice in the above-captioned matter.
+
+2. I have not been convicted of a felony.
+
+3. I have not been censured, suspended, disbarred, or denied admission or readmission by any court.
+
+4. There are no pending disciplinary proceedings against me in any State or Federal court.
+
+Wherefore J. Orrico respectfully submits that he be permitted to appear as counsel and advocate pro hac vice in this one case.
+
+Dated: August 8, 2023
+
+anco
+
+J. Orrico
+
+GRANT & EISENHOFER P.A.
+
+485 Lexington Ave. 29th floor
+
+New York, NY 10017
+
+corrico@gelaw.com
+
+(302) 622-7067
+
+Operating Engineers Construction Industry and Miscellaneous Pension Fund
\ No newline at end of file
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+![](_page_0_Picture_76.jpeg)
+
+*Appellate Division of the Supreme Court  
+of the State of New York  
+First Judicial Department*
+
+---
+
+I, Susanna M. [REDACTED], Clerk of the Appellate Division of the Supreme Court of the State of New York, First Judicial Department, do hereby certify that
+
+[REDACTED] John Orrico
+
+was duly licensed and admitted to practice as an Attorney and Counselor at Law in all the courts of this State on **January 11, 2010**, has duly taken and subscribed the oath of office prescribed by law, has been enrolled in the Roll of Attorneys and Counselors at Law on file in this office, is duly registered with the Administration Office of the Courts, and according to the records of this Court is currently in good standing as an Attorney and Counselor-at-Law.
+
+![](_page_0_Picture_81.jpeg)
+
+In Witness Whereof, I have hereunto set my hand in the City of New York on July 13, 2023.
+
+![]()*Clerk of the Court*
+
+CertID-00128364
+
+![](_page_1_Picture_100.jpeg)
+
+**Supreme Court of the State of New York  
+Appellate Division, First Department**
+
+ROLANDO T. ACOSTA  
+PRESIDING JUSTICE
+
+SUSANNA MOLINA [REDACTED]  
+CLERK OF THE COURT
+
+MARGARET SOWAH  
+DEPUTY CLERK OF THE COURT
+
+To Whom It May Concern
+
+An attorney admitted to practice by this Court may request a certificate of good standing, which is the only official document this Court issues certifying to an attorney's admission and good standing.
+
+An attorney's registration status, date of admission and disciplinary history may be viewed through the attorney search feature on [the website of the Unified Court System](#).
+
+New York State does not register attorneys as active or inactive.
+
+An attorney may request a disciplinary history letter from the [Attorney Grievance Committee of the First Judicial Department](#).
+
+Bar examination history is available from the [New York State Board of Law Examiners](#).
+
+Instructions, forms and links are available on [this Court's website](#).
+
+![]()Susanna [REDACTED]  
+Clerk of the Court
+
+Revised October 2020
+
+## State of Connecticut Supreme Court
+
+I, Carl D. Cicchetti, Chief Clerk of the Supreme Court of the State of Connecticut and keeper of the Seal thereof
+
+Do hereby certifr, that, in the Supreme Court at on the 6th day of November, 2009 Hartford
+
+John Orrico
+
+of
+
+Chatham, NJ
+
+having been examined and found duly qualified, was sworn as an attorney and admitted to practice before all courts of this state, and that said attorney is a member of in good standing of the Bar of this State pursuant to Practice Book §2-65.
+
+![](_page_2_Picture_8.jpeg)
+
+In Testimony Whereof I have hereunto set my hand and affix the Seal of the Supreme Court of the State of Connecticut, at Hartford, this day July 21, 2023
+
+Carl D. Cicchetti Chief Clerk
\ No newline at end of file
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+Case No. 1:23-CV-03903 (JSR)
+
+## DERIVATIVE ACTION
+
+[PROPOSED] ORDER FOR ADMISSION PRO HAC VICE
+
+The motion of J. Orrico for admission to practice pro hac vice in the abovecaptioned action is GRANTED.
+
+Applicant has declared that he is a member in good standing of the bars of the State of New York and the State of Connecticut, and that his contact information is as follows:
+
+Name: J. Orrico Firm Name: Grant & Eisenhofer P.A. Address: 485 Lexington Ave. 29th floor City/State/Zip: New York, NY 10017 Email: corrico@gelaw.com Telephone: (302) 622-7067
+
+Applicant having requested admission pro hac vice to appear for all purposes as counsel for plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund in the above-captioned action,
+
+IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned case in the United States District Court for the Southern District of New York.
+
+All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys.
+
+Dated: August .2023 New York, NY
+
+JED S. RAKOFF, U.S.D.J.
\ No newline at end of file
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+Case No. 1:23-CV-03903-(JSR)
+
+## DERIVATIVE ACTION
+
+## MOTION FOR ADMISSION PRO HAC VICE
+
+Pursuant to Rule 1.3(c) of the Local Rules of the United States District Courts for the Southern and Eastern Districts of New York, I, J. Orrico, hereby move this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund in the above-captioned action.
+
+I am in good standing with the bar of the State of New York and the bar of the State of Connecticut and there are no disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3.
+
+Dated: August 8, 2023 Respectfully submitted,
+
+s/ J Onto
+
+J. Orrico
+
+GRANT & EISENHOFER P.A.
+
+485 Lexington Ave. 29'h floor
+
+New York, NY 10017
+
+corrico@gelaw.com
+
+(302) 622-7067
+
+Operating Engineers Construction Industry and Miscellaneous Pension Fund
\ No newline at end of file
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+I, correct: J. Orrico, declare under penalty of perjury that the following is true and
+
+Case No. I :23-CV-03903-(JSR)
+
+## DERIVATIVE ACTION
+
+## DECLARATION OF
+
+## J. ORRICO IN SUPPORT OF APPLICATION FOR ADMISSION PRO HAC VICE
+
+I. I am a Partner/Principal with the law firm of Grant & Eisenhofer P.A. I am eligible to practice and a member in good standing in the State of New York and in the State of Connecticut. Certificates of Good Standing are appended hereto. I submit this declaration in support of my motion for admission to practice pro hac vice in the above-captioned matter.
+
+2. I have not been convicted of a felony.
+
+3. I have not been censured, suspended, disbarred, or denied admission or readmission by any court.
+
+4. There are no pending disciplinary proceedings against me in any State or Federal court.
+
+Wherefore J. Orrico respectfully submits that he be pennitted to appear as counsel and advocate pro hac vice in this one case.
+
+Dated: August 8, 2023
+
+![]()Christopher J. Orrico  
+**GRANT & EISENHOFER P.A.**  
+485 Lexington Ave. 29<sup>th</sup> floor  
+New York, NY 10017  
+corrico@gelaw.com  
+(302) 622-7067  
+*Operating Engineers Construction Industry  
+and Miscellaneous Pension Fund*
+
+SUBSCRIBED and SWORN TO BEFORE ME
+
+This 8 day of August 2023
+
+![]()My commission expires: 9/2/24
+
+![](_page_1_Picture_26.jpeg)
\ No newline at end of file
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+![](_page_0_Picture_76.jpeg)
+
+*Appellate Division of the Supreme Court  
+of the State of New York  
+First Judicial Department*
+
+---
+
+I, Susanna M. [REDACTED], Clerk of the Appellate Division of the Supreme Court of the State of New York, First Judicial Department, do hereby certify that
+
+[REDACTED] John Orrico
+
+was duly licensed and admitted to practice as an Attorney and Counselor at Law in all the courts of this State on **January 11, 2010**, has duly taken and subscribed the oath of office prescribed by law, has been enrolled in the Roll of Attorneys and Counselors at Law on file in this office, is duly registered with the Administration Office of the Courts, and according to the records of this Court is currently in good standing as an Attorney and Counselor-at-Law.
+
+![](_page_0_Picture_81.jpeg)
+
+In Witness Whereof, I have hereunto set my hand in the City of New York on July 13, 2023.
+
+![]()*Clerk of the Court*
+
+CertID-00128364
+
+![](_page_1_Picture_20.jpeg)
+
+**Supreme Court of the State of New York  
+Appellate Division, First Department**
+
+ROLANDO T. ACOSTA  
+PRESIDING JUSTICE
+
+SUSANNA MOLINA [REDACTED]  
+CLERK OF THE COURT
+
+MARGARET SOWAH  
+DEPUTY CLERK OF THE COURT
+
+To Whom It May Concern
+
+An attorney admitted to practice by this Court may request a certificate of good standing, which is the only official document this Court issues certifying to an attorney's admission and good standing.
+
+An attorney's registration status, date of admission and disciplinary history may be viewed through the attorney search feature on [the website of the Unified Court System](#).
+
+New York State does not register attorneys as active or inactive.
+
+An attorney may request a disciplinary history letter from the [Attorney Grievance Committee of the First Judicial Department](#).
+
+Bar examination history is available from the [New York State Board of Law Examiners](#).
+
+Instructions, forms and links are available on [this Court's website](#).
+
+![]()Susanna [REDACTED]  
+Clerk of the Court
+
+Revised October 2020
+
+## State of Connecticut Supreme Court
+
+I, Carl D. Cicchetti, Chief Clerk of the Supreme Court of the State of Connecticut and keeper of the Seal thereof
+
+Do hereby certify, that, in the Supreme Court at on the 6th day of November, 2009 Hartford
+
+John Orrico
+
+of
+
+Chatham, NJ
+
+having been examined and found duly qualified, was sworn as an attorney and admitted to practice before all courts of this state, and that said attorney is a member of in good standing of the Bar of this State pursuant to Practice Book §2-65.
+
+![](_page_2_Picture_8.jpeg)
+
+In Testimony Whereof I have hereunto set my hand and affix the Seal of the Supreme Court of the State of Connecticut, at Hartford, this day July 21, 2023
+
+Carl D. Cicchetti Chief Clerk
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+Case No. 1:23-CV-03903 (JSR)
+
+## DERIVATIVE ACTION
+
+[PROPOSED] ORDER FOR ADMISSION PRO HAC VICE
+
+The motion of J. Orrico for admission to practice pro hac vice in the abovecaptioned action is GRANTED.
+
+Applicant has declared that he is a member in good standing of the bars of the State of New York and the State of Connecticut, and that his contact information is as follows:
+
+Name: J. Orrico Firm Name: Grant & Eisenhofer P.A. Address: 485 Lexington Ave. 29th floor City/State/Zip: New York, NY 10017 Email: corrico@gelaw.com Telephone: (302) 622-7067
+
+Applicant having requested admission pro hac vice to appear for all purposes as counsel for plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund in the above-captioned action,
+
+IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned case in the United States District Court for the Southern District of New York.
+
+All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys.
+
+Dated: August .2023 New York, NY
+
+JED S. RAKOFF, U.S.D.J.
\ No newline at end of file
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+**IN THE UNITED STATES DISTRICT COURT  
+FOR THE SOUTHERN DISTRICT OF NEW YORK**
+
+IN RE JP [REDACTED] CHASE & CO.  
+DERIVATIVE LITIGATION
+
+[REDACTED] Case No. 1:23-CV-03903-(JSR)
+
+**DERIVATIVE ACTION**
+
+**MOTION FOR ADMISSION  
+PRO HAC VICE**
+
+Pursuant to Rule 1.3(c) of the Local Rules of the United States District Courts for the Southern and Eastern Districts of New York, I, [REDACTED] J. Orrico, hereby move this Court for an Order for admission to practice *Pro Hac Vice* to appear as counsel for plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund in the above-captioned action.
+
+I am in good standing with the bar of the State of New York and the bar of the State of Connecticut and there are no disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3.
+
+Dated: August 8, 2023
+
+Respectfully submitted,
+
+![]()Christopher J. Orrico  
+**GRANT & EISENHOFER P.A.**  
+485 Lexington Ave. 29<sup>th</sup> floor  
+New York, NY 10017  
+corrico@gelaw.com  
+(302) 622-7067  
+*Operating Engineers Construction  
+Industry and Miscellaneous Pension  
+Fund*
\ No newline at end of file
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+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+CITY OF MIAMI GENERAL EMPLOYEES & SANITATION EMPLOYEES RETIREMENT TRUST and OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND
+
+Plaintiff,
+
+-v-
+
+JAMES DIMON, STEPHEN B. TODD A. COMBS, JAMES S. CROWN, TIMOTHY P. FLYNN, MELLODY HOBSON, JOHN W. KESSLER, PHEBE N. NOVAKOVIC, and JAMES E. STALEY,
+
+Defendants,
+
+and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+JED S. RAKOFF, U.S.D.J.:
+
+23-cv-03903 (JSR)
+
+ORDER
+
+On July 6, 2023, defendants James Dimon, Stephen B. , Todd A. Combs, James S. Crown, Timothy P. Flynn, Mellody Hobson, John W. Kessler, Phebe N. Novakovic, and James E. Staley and nominal defendant JPMorgan Chase & Co. ("JPMorgan") filed motions to dismiss the operative complaints in the above-captioned cases. See Dkt. 24; Dkt. 28. Upon consideration of all parties' written submissions, the Court hereby grants those motions on the ground that plaintiffs have failed to make pre-suit demand on the board of directors of JPMorgan or adequately allege that doing so would be futile. In light of this conclusion, Court does not reach defendants' motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b) (6) for failure to state a claim upon which relief may be granted.
+
+An opinion explaining the reasons for these rulings will follow in due course, at which time judgment will be entered.
+
+The Clerk of the Court is respectfully directed to close entry numbers 24 and 28.
+
+SO ORDERED.
+
+New York NY
+
+August , 2023 K FF, U.S.D.J.
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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND.
+
+Plaintiff,
+
+v.
+
+JAMES DIMON, ASHLEY BACON, LINDA'. BAMMANN, JAMES A. BELL, JOHN H. BIGGS. CRANDALL C. BOWLES, STEPHEN,. TODD A. COMBS, DAVID M. COTE, JAMES S. CROWN, MARY C. ERDOES, TIMOTHY P. FLYNN, ELLEN V. FUTTER, MELLODY HOBSON, JOHN J. HOGAN, LABAN P. , JR., JOHN W. KESSLER, ROBERT I. LIPP, RICHARD A. MANOOGIAN, MICHAEL A. NEAL, DAVID C. NOVAK, LEE R. RAYMOND, JAMES E. STALEY, WILLIAM C. WELDON, and BARRY L. ZUBROW,
+
+Defendants,
+
+and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+Case Number: 1:23-cv-03903-JSR
+
+[PROPOSED] ORDER GRANTING MOTION FOR ADMISSION PRO HAC VICE
+
+The motion of John McNichols for admission to practice pro hac vice in the abovecaptioned action is GRANTED. Applicant has declared that he is a member in good standing of the bars of the District of Columbia, Virginia, and Maryland and that his contact information is as follows:
+
+Applicant's Name: John McNichols
+
+Firm Name: & Connolly LLP
+
+Address: 680 Maine Avenue, S.W.
+
+City/State/Zip: Washington, D.C. 20024
+
+Telephone/Fax: (202) 434-5043 / (202) 434-5029
+
+Email: JMcnichols@wc.com
+
+Applicant having requested admission pro hac vice to appear for all purposes as counsel for Defendant James Edward Staley in the above-captioned action:
+
+IT IS HEREBY ORDERED that Applicant John McNichols is admitted to practice pro hac vice in the above-captioned action in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys.
+
+Dated: 11/7/2023 9
+
+0413. 4/Z179 Honorable Jed akoff United States District Judge
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+## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+IN RE JP CHASE & CO. DERIVATIVE LITIGATION
+
+Case No. 1:23-CV-03903 (JSR)
+
+## DERIVATIVE ACTION
+
+## [PROPOSED] ORDER FOR ADMISSION PRO HAC VICE
+
+The motion of J. Orrico for admission to practice pro hac vice in the abovecaptioned action is GRANTED.
+
+Applicant has declared that he is a member in good standing of the bars of the State of New York and the State of Connecticut, and that his contact information is as follows:
+
+Name: J. Orrico Firm Name: Grant & Eisenhofer P.A. Address: 485 Lexington Ave. 29th floor City/State/Zip: New York, NY 10017 Email: corrico@gelaw.com Telephone: (302) 622-7067
+
+Applicant having requested admission pro hac vice to appear for all purposes as counsel for plaintiff Operating Engineers Construction Industry and Miscellaneous Pension Fund in the above-captioned action,
+
+IT IS HEREBY ORDERED that Applicant is admitted to practice pro hac vice in the above-captioned case in the United States District Court for the Southern District of New York.
+
+All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys.
+
+Dated: November 7, .2023  
+New York, NY
+
+*Jed S. Rakoff, U.S.D.J.*  
+JED S. RAKOFF, U.S.D.J.
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+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+CITY OF MIAMI GENERAL EMPLOYEES & SANITATION EMPLOYEES RETIREMENT TRUST and OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND
+
+Plaintiffs,
+
+-v-
+
+JAMES DIMON, STEPHEN B. TODD A. COMBS, JAMES S. CROWN, TIMOTHY P. FLYNN, MELLODY HOBSON, JOHN W. KESSLER, PHEBE N. NOVAKOVIC, and JAMES E. STALEY,
+
+Defendants,
+
+and
+
+JPMORGAN CHASE & CO.,
+
+Nominal Defendant.
+
+JED S. RAKOFF, U.S.D.J.:
+
+23-cv-03903 (JSR)
+
+OPINION AND ORDER
+
+This is a derivative action brought by shareholders of JPMorgan Chase & Co. ("JPMorgan") against various officers and directors of JPMorgan. The amended complaint asserts claims for breach of fiduciary duty and unjust enrichment, based upon allegations that the defendants caused JPMorgan to retain Jeffrey Epstein as a client of the bank long after defendants knew -- or should have known -- that Epstein was using the bank's financial services to facilitate Epstein's criminal sex trafficking and exploitation of women and underaged girls. JPMorgan recently entered into two court-approved settlements concerning this
+
+activity --one with a class of Epstein victims and another with the Government of the United States Virgin Islands -- in which JPMorgan has agreed to pay a total of \$365 million. Plaintiffs seek to hold the defendants liable for causing this and other harms to the company.
+
+On July 6, 2023, defendants moved to dismiss the amended complaint in its entirety, arguing both that plaintiffs' amended complaint fails to state a claim pursuant to Federal Rule of Civil Procedure 12(b) (6) and that plaintiffs have failed to adequately allege that they are excused from making a pre-suit demand on JPMorgan's board of directors. See Dkt. 24; Dkt. 28. On August 9, 2023, this Court granted defendants' motions by "bottom-line" Order. See Dkt. 39. That Order noted that the Court did not reach defendants' motion pursuant to Rule 12(b) (6) because the Court found that the amended complaint failed to adequately allege that it would have been futile to make a pre-suit demand on JPMorgan's board. This Opinion sets forth more fully the reasons for that ruling.'
+
+## I. Legal Standard
+
+Under Delaware law, applicable here because JPMorgan is a Delaware corporation, "the board's authority to govern corporate affairs extends to decisions about what remedial actions a corporation should take after being harmed, including whether the corporation should file a lawsuit against its directors, its officers, its controller, or an outsider." United Food & Com. Workers Union & Participating Food Indus.
+
+The Court's August 9, 2023, Order noted that judgment would not be entered until the issuance of this Opinion.
+
+Emps. Tri-State Pension Fund v. Zuckerberg, 262 A.3d 1034, 1047 (Del. 2021); see also Aronson v. , 473 A.2d 805, 811 (Del. 1984) ("A cardinal precept of [Delaware corporations law] is that directors, rather than shareholders, manage the business and affairs of the corporation."). "In order for a stockholder to divest the directors of their authority to control the litigation asset and bring a derivative action (1) make a demand demand would be on behalf of the corporation, the stockholder must on the company's board of directors or (2) show that futile." Zuckerberg, 262 A.3d at 1047 (internal quotation omitted).
+
+The plaintiffs here did not make a demand on the JPMorgan board before bringing suit, and so plaintiffs must allege that making a litigation demand on JPMorgan's board would have been futile. To do this, a plaintiff must allege that a majority of the members of JPMorgan's board, at the time the complaint was filed, would have been unable to disinterestedly consider a litigation demand. A plaintiff may show a given director is unable to disinterestedly consider a litigation demand in one of three ways: (1) the director "received a material personal benefit from the alleged misconduct," (2) the director "would face a substantial likelihood of liability on any of the claims," or (3) the director "lacks independence from someone" conflicted under (1) or (2). Id. at 1058. Pursuant to Federal Rule of Civil Procedure 23.1, allegations of demand futility must be pled "with particularity." F5 Cap. v. Pappas, 856 F.3d 61, 82-83 (2d Cir. 2017) (quoting Fed. R. Civ. P. 23.1(b)(3)).
+
+In evaluating whether the director defendants face a substantial likelihood of liability on plaintiffs' claims, it is significant that JPMorgan's corporate charter -- in line with the virtually uniform practice of public corporate charters today -- contains a provision exculpating directors from liability for breaches of fiduciary duty except where they arise from acts taken in bad faith or as a result of intentional misconduct. See Soloway Decl. Ex. 2 (Dkt. 26-2), at 4; see also Del. Gen. Corp. L. § 102(b) (7) (authorizing such provisions). Therefore, to establish a substantial likelihood of liability, it is not enough to establish a breach of the duty of care, but rather plaintiff must allege "conduct that is not in good faith or a breach of the duty of loyalty." ex rel. AmSouth Bancorporation v. Ritter, 911 A.2d 362, 367 (Del. 2006).
+
+The amended complaint alleges that the director-defendants breached the duty of loyalty by failing to adequately oversee the affairs of the corporation. Such a theory is often referred to as a "Caremark claim" after the seminal Delaware case elaborating the theory, and has been described as "possibly the most difficult theory in corporation law upon which a plaintiff might hope to win a judgment." In re Caremark Int'l Inc. Derivative Litig., 698 A.2d 959, 967 (Del. Ch. 1996). To make out a Caremark claim, a plaintiff must establish that either "(a) the directors utterly failed to implement any reporting or information system or controls; or (b) having implemented such a system or controls, consciously failed to monitor or oversee its operations thus disabling themselves from being informed
+
+of risks or problems requiring their attention." , 911 A.2d at 370. Whether proceeding under either or both of these theories, it is necessary that a plaintiff show the directors were acting in bad faith, in the sense that the directors actually "knew that they were not discharging their fiduciary obligations." City of Detroit Police & Fire Ret. Sys. ex rel. NiSource, Inc. v. Hamrock, 2022 WL 2387653, at \*11 (Del. Ch. June 30, 2022) (quoting id.).
+
+## II. Discussion
+
+At the time the plaintiffs filed suit, JPMorgan's board was comprised of twelve directors, and so to plead demand futility plaintiff must adequately allege that at least six directors were conflicted.2 Of the twelve demand directors, only four were even on JPMorgan's board while Epstein was a client of the bank -- JPMorgan terminated Epstein as a client in 2013. Am. Compl. 1 3. Plaintiffs allege that one of these four directors, CEO and board chairman Jamie Dimon, was aware of Epstein's misconduct, and yet failed to take action to eliminate Epstein as a client sooner. See Pls. Opp. at 9-11. With
+
+<sup>2</sup>One of JPMorgan's directors, James Crown, passed away between when the original complaint in this case was filed and when the amended complaint was filed. See Suggestion of Death (Dkt. 23) (noting Crown died five days before amended complaint was filed). While, as a general matter, demand futility is assessed based on the board's composition at the time the operative complaint is filed, a plaintiff who amends its complaint may rely on the board's composition at the time of a prior complaint if the derivative claims asserted in the amended complaint were already "validly in litigation." Braddock v. Zimmerman, 906 A.2d 776, 785-86 (Del. 2006). Determining whether a claim is "validly in litigation" requires application of a three-part test that generally evaluates the sufficiency of the prior complaint's derivative allegations. See Barenbaum ex rel. FTE Networks, Inc. v. Palleschi, 2020 WL 5819810, at \*8 (S.D.N.Y. Sept. 30, 2020). Both parties fail to cite the relevant legal standard or provide any analysis about how this test applies here. Accordingly, the Court will assume without deciding that Crown should be included within the composition of the relevant demand board because the Court finds plaintiffs' claims fail even if he is.
+
+respect to the other three directors in this category -- Stephen James Crown, and Timothy Flynn -- plaintiffs allege that they utterly failed to implement an effective board-level system of reporting to oversee compliance with the Bank Secrecy Act and anti-money laundering laws, and as a result failed to detect the bank's facilitation of Epstein's misconduct. See Pls. Opp. at 11-16. While defendants vigorously dispute whether even these directors face a substantial likelihood of liability, the Court need not resolve this question because the Court finds that plaintiffs have failed to allege with particularity that any of the remaining eight directors are conflicted.
+
+Of the remaining eight directors, plaintiffs concede that four are disinterested and capable of considering a litigation demand. With respect to the other four such directors -- Linda Bammann, Todd Combs, Michael Neal, and Phebe Novakovic -- plaintiffs make two arguments. First, plaintiffs argue that Bammann, Combs and Neal are conflicted because they face a substantial likelihood of liability. Second, plaintiffs argue that Bammann and Novakovic are conflicted because they each lack independence from one or another director who was on JPMorgan's board while Epstein was a client -- Jamie Dimon and James Crown, respectively. As explained below, the Court finds neither argument plausible.
+
+## A. Substantial Likelihood of Liability of Bammann, Combs and Neal.
+
+Plaintiffs claim that Bammann, Combs and Neal face a substantial likelihood of liability. However, none of these three directors were on JPMorgan's board of directors while Epstein was a client, and so
+
+they cannot be accused of failing to eliminate Epstein as a client. Rather, as articulated in plaintiffs' opposition brief, plaintiffs' theory of liability with respect to these directors centers around a deferred prosecution agreement ("DPA") the company entered into with the U.S. Department of Justice ("DOJ") in 2014 in connection with JPMorgan's completely unrelated facilitation of Bernie Madoff's Ponzi scheme and a similar, related consent order ("Consent Order") JPMorgan entered into with the Office of the Comptroller of the Currency ("0CC"). See Pls. Opp. at 16-18.
+
+Plaintiffs observe that, in the DPA and Consent Order, JPMorgan "agreed to (i) implement an exhaustive review of all past [suspicious activity report, or "SAR"] filings and ensure that any other potentially suspicious activity was identified and reported, (ii) review all transactions by non-bank financial institutions, and (iii) oversee these reviews, with written findings `reported to the Board.'" Pls. Opp. at 16-17 (quoting Soloway Decl. Ex. 1 (Dkt. 26-1) Art. VIII, IX). The DPA also required JPMorgan to report any criminal conduct or violations of the Bank Secrecy Act to the DOJ. Soloway Decl. Ex. 1 (Dkt. 26-2) 911 10, 20.
+
+Plaintiffs argue that it is "reasonable to infer" that JPMorgan management complied with the DPA's obligations to review past transactions and thereby learned of the alleged failures to file SARs regarding Epstein. Pls. Opp. at 17. From this, plaintiffs claim that "[i]t logically follows that it is reasonably inferable that the post-DPA Board members . . . learned of JPM's failure to timely file
+
+Epstein-related SARs and of Epstein's criminal conduct more generally." Id. Having supposedly learned this information, plaintiffs further argue the aforementioned directors breached their fiduciary duties by failing to report Epstein's misconduct to the DOJ or file a belated SAR, thereby breaching the DPA and Consent Order. Id.
+
+Plaintiffs' argument is riddled with holes. First, the amended complaint's allegations do not line up with the argument outlined above. The amended complaint contains only a single, off-hand reference to the DPA and Consent Order and does so to suggest that, more generally, the company's compliance infrastructure was inadequate. See Am. Compl. III 170-71. The amended complaint contains no discussion of the DPA's or Consent Order's contents, does not allege that the review conducted under the DPA uncovered Epstein-related issues and does not allege that any uncovered information about Epstein was passed on to the board. Plaintiffs cannot amend their complaint through their opposition papers, especially where, as here, plaintiffs were required by Rule 23.1 to plead particularized facts to support demand futility.
+
+Second, even assuming these allegations had been included in the complaint, the inferences plaintiffs ask this court to draw from them are simply not plausible. It is not at all clear that the review of past money laundering filings mandated by the DPA and Consent Order uncovered Epstein-related conduct. The Consent Order required that the review "be supervised and certified by independent consultant(s) acceptable to the Examiner-in-Charge" -- a third-party reviewer appointed under the Consent Order -- and the results of the review
+
+were to be reported to the Examiner-in-Charge. Mackintosh Decl. Ex. 1 (Dkt. 31-1) Art. VII, Sec. (2)-(3). Plaintiff asks the Court to implausibly infer that both the independent consultant and the independent examiner appointed under the Consent Order became aware of the Epstein-related conduct and yet were complicit in the company's alleged continued failure to file SARs relating to it.
+
+Even assuming hypothetically that the review did identify the Epstein-related conduct, there is no reason to think that information was transmitted to the board. As the amended complaint acknowledges, JPMorgan is "one of the world's largest financial institutions." Am. Compl. \$ 2. While the DPA did require the written findings of the review be reported to the board, it does not follow the board would have received information about every single client who was the subject of concerns. Indeed, if anything, the amended complaint seems to contradict any inference that the board was made aware, alleging "there is no evidence that JPM's board of directors . . . ever discussed Epstein prior to his death by apparent suicide in 2019." Am. Compl. 1 3. Thus, the Court cannot reasonably infer that these three board members were made aware of the company's alleged failure to file Epstein-related SARs.3
+
+<sup>3</sup>The absence of any allegation of actual evidence of the board's knowledge defeats any claim under the second prong of Caremark, which requires proof "the board knew of evidence of corporate misconduct -- the proverbial `red flag' -- yet acted in bad faith by consciously disregarding its duty to address that misconduct." Teamsters Loc. 443 Health Servs. & Ins. Plan v. Chou, 2020 WL 5028065, at \*17 (Del. Ch. Aug. 24, 2020) (quotation omitted). To the extent plaintiffs' claim these directors are liable pursuant to the first prong of Caremark, requiring allegations of "an utter failure to attempt to assure a reasonable information and reporting system exists," the very existence of the Consent Order and DPA would defeat such a claim, because both agreements expressly required a reporting system be established.
+
+Third, even setting aside these factual deficiencies, plaintiffs have failed to explain how the purported breach of fiduciary duty - permitting a violation of the DPA/Consent Order and failure to correct previously-deficient SAR filings regarding Epstein -- actually caused the company any harm. To reiterate, these directors cannot be accused of failing to terminate Epstein as a client, because the company had already done so by the time they joined the board. And plaintiffs do not allege that JPMorgan was ever penalized by the DOJ or OCC for violating the DPA or Consent Order (or even that either government agency found a violation), so even assuming a violation of those agreements occurred in the abstract, it is not clear how that would support liability for the Epstein-related conduct. Nor do plaintiffs explain why failure to correct previously deficient SAR filings between 2014 and 2016 -- after Epstein was no longer a client -- caused the company any harm. In short, plaintiffs have failed to allege -- let alone allege with particularity -- facts giving rise to a reasonable inference that Bammann, Combs and Neal face a substantial likelihood of liability.4
+
+Hamrock, 2022 WL 2387653, at \*12 (quotation omitted) (noting that a plaintiff that attempts to allege a Caremark claim under both prongs typically loses under prong one "because the plaintiff must concede the existence of a board-level monitoring system to plead under prong two").
+
+<sup>4</sup>The absence of any allegation that that JPMorgan was penalized for violating the DPA or Consent Order distinguishes this case from the two authorities cited by plaintiffs, both of which involved situations where a company entered into a consent decree requiring board-level reporting, violated that consent decree, and then were later penalized for those violations. See Westmoreland Cnty. Emp. Ret. Sys. v. Parkinson, 727 F.3d 719, 727 (7th Cir. 2013); In re Pfizer Inc. S'holder Derivative Litig., 722 F. Supp. 2d 453, 461-62 (S.D.N.Y. 2010). The absence of particularized factual allegations here is, of course, another distinguishing factor.
+
+## B. Independence of Novakovic & Bammann
+
+The amended complaint offers one final route to establish demand futility. It claims that Novakovic and Bammann lack independence from directors facing a substantial likelihood of liability because they were on the board while Epstein was a client of the bank. If plaintiffs are correct that both of these directors lack independence, then demand would be excused (again assuming arguendo that the four directors on the board while Epstein was a client face a substantial likelihood of liability). But as explained below, the Court finds plaintiffs have failed to allege either Novakovic or Bammann lack independence such that they are incapable of disinterestedly considering a litigation demand.
+
+In evaluating demand futility, "directors are presumed to be independent." Teamsters Union 25 Health Servs. & Ins. Plan v. Baiera, 119 A.3d 44, 59 (Del. Ch. 2015) (internal quotation marks omitted). To overcome this presumption, plaintiffs must allege with particularity "facts from which the director's ability to act impartially on a matter important to the interested party can be doubted because that director may feel either subject to the interested party's dominion or beholden to that interested party." F5 Cap. v. Pappas, 856 F.3d 61, 84 (2d Cir. 2017) (quoting Sandys v. Pincus, 152 A.3d 124, 128 (Del. 2016)). In making this determination, the Court may not view each of the amended complaint's allegations in isolation but must instead consider them wholistically. See id. at 83.
+
+Bammann. Plaintiffs argue Bammann is not disinterested because she has extensive professional ties to Jamie Dimon, the CEO of JPMorgan and Chairman of its board. From 2001 to 2004 Bammann was an executive at another company called Bank One while Dimon was the CEO of Bank One. Am. Compl. 1 193. And then, after Bank One was acquired by JPMorgan, Bammann served as JPMorgan's deputy head of risk management while Dimon was President and COO of JPMorgan. Id. Finally, plaintiffs allege Bammann joined the JPMorgan board while Dimon was CEO and chairman of JPMorgan in 2013, and that since then Bammann's only source of income has been her role on the board. Id.
+
+The mere fact that Bammann and Dimon worked together at One Bank and JPMorgan does not give rise to an inference that Bammann is disabled from considering a litigation demand against Dimon. See, e.g., F5 Cap., 856 F.3d at 85 (noting that a "mere personal friendship or outside business relationship does not raise a reasonable doubt about a director's independence" and concluding allegations that directors served on several other boards together and had "substantial business entanglements" did not call into question director's independence (internal quotation marks omitted)); Orman v. Cullman, 794 A.2d 5, 27 (Del. Ch. 2002) ("[A]llegations concerning longstanding business relations fail as a matter of law to place in issue the independence of directors .
+
+Nor is the bare allegation that Bammann joined the board while Dimon was CEO and Chairman sufficient to rebut the presumption of independence. Delaware courts have repeatedly found that even where a director is appointed at the behest of a company's controlling shareholder -- a far more extreme scenario than that presented here - - the fact of a director's appointment alone does not rebut the presumption of independence, since that is simply how the normal process of nominating directors operates in such instances. See McElrath v. Kalanick, 224 A.3d 982, 995 (Del. 2020) ("Importantly, being nominated or elected by a director who controls the outcome is insufficient by itself to reasonably doubt a director's independence because that is the usual way a person becomes a corporate director." (internal quotation marks omitted); Baiera, 119 A.3d at 60-61 (same). The fact that Bammann's sole employment since 2013 as been her service on JPMorgan's board does not alter this conclusion, given that plaintiffs have not explained why this compensation would be imperiled were she to consider a litigation demand or alleged that the amount she is paid is particularly significant to her overall financial prosperity. See Simons v. Brookfield Asset Mgmt. Inc., 2022 WL 223464, at \*15 (Del. Ch. Jan. 21, 2022) ("[M]ere allegations of payment of director fees are insufficient to create a reasonable doubt as to the director's independence."); Halpert Enter., Inc. v. 362 F. Supp. 2d 426, 433 (S.D.N.Y.2005) ("The allegations that the Board members receive various fees from (the company] are similarly unavailing, because there are no particularized allegations indicating that that compensation is excessive.").
+
+Plaintiffs argue that the relationship between Bammann and Dimon goes beyond a normal professional relationship because Bammann "owes
+
+a significant portion of her professional success to Dimon." Pls. Opp. at 19. But the amended complaint's allegations do not support this claim. Nowhere does the amended complaint actually allege, let alone offer particularized factual allegations, how Bammann's professional advancement was the result of Dimon's influence. Rather, plaintiffs' argument is based solely on the circumstantial inference that, because Bammann and Dimon had overlapping upward trajectories at One Bank and JPMorgan, Dimon must have been the cause. But these allegations at most establish that it is conceivable Dimon played a role in Bammann's advancement, and pleading conceivability alone is insufficient even under Federal Rule of Civil Procedure 8(a)'s more permissive pleading standard. See Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007) (complaint must allege sufficient factual matter to "nudged (plaintiffs') claims across the line from conceivable to plausible").
+
+The inference that Bammann owes some professional debt to Dimon is further undermined by the fact that their time serving together as managers occurred over a decade ago. While plaintiff responds that "past benefits conferred . . . may establish an obligation or debt," Pls. Opp. at 20, the age of any such obligation remains relevant. Absent more particularized allegations about the nature of the debt of gratitude Bammann supposedly owes to Dimon, the Court is unable to reasonably infer that such a debt was so substantial as to imperil Bammann's independence so many years later. In short, even when taken as a whole, plaintiffs' threadbare allegations are insufficient to
+
+give rise to a reasonable inference that Bammann lacks independence from Dimon.
+
+Novakovic. Plaintiffs argue Novakovic lacks independence from Crown, who was among the directors on the board at the time Epstein was a client. Novakovic is the CEO and Chairman of another company, General Dynamics, which the amended complaint describes as "affiliated with the Crown family," and as a "Crown[] family business." Am. Compl. 55 36, 195. The amended complaint also alleges Novakovic served on the General Dynamics board with Crown. Id. 1 33. Plaintiffs claim that, as a result of the Crown-family's control of General Dynamics, Novakovic is beholden to Crown and therefore could not disinterestedly consider a litigation demand against him. See Pls. Opp. at 19.
+
+Plaintiffs have failed to allege that Crown's and Novakovic's ties to General Dynamics rise beyond the general business relationships that are otherwise insufficient to establish a lack of independence. See supra. While plaintiffs claim that, because General Dynamics is "Crown's family business," Crown "likely had the influence to fire Novakovic" from her position as General Dynamics CEO, Am. Compl. 1 194, plaintiffs offer no particularized allegations to support this contention that Crown had the unilateral power to fire Novakovic or that Crown exercised significant influence over the direction of the company. See Flannery v. Genomic Health, Inc., 2021 WL 3615540, at \*15 (Del. Ch. Aug. 16, 2021) (concluding allegation director had "significant investments" in employer of director was insufficient where complaint failed to allege whether those investments gave the
+
+"unilateral power" to control the directors compensation). General Dynamics is not a privately held family business but a publicly traded Fortune 100 company, and it is simply not plausible, based on the conclusory allegations in the amended complaint, to conclude Crown had sufficient power over Novakovic's employment at General Dynamics so as to render Novakovic not disinterested.<sup>5</sup>
+
+\* \* \* \* \*
+
+For the reasons set forth above, the Court grants the motions to dismiss. Because the plaintiffs have already amended their complaint and because, even based on the additional allegations referenced in their reply papers, the complaint would still have to be dismissed, the dismissal is with prejudice. Accordingly, the Court hereby dismisses the case with prejudice. The Clerk of the Court is directed to enter final judgment forthwith and close the case.
+
+SO ORDERED.
+
+New York, NY  
+January 12, 2024
+
+![]()
+
+---
+
+<sup>5</sup> Indeed, the absence of any particularized allegations of control of General Dynamics by the Crown is likely because they would be counterfactual. According to General Dynamic's 2023 proxy statement, as of March 2023 Crown directly owned under .5% of the Company's shares and was potentially the indirect beneficial owner of slightly over 5% of shares. See General Dynamics Proxy Statement, at 88-89 (Mar. 24, 2023), available at <https://d18rn0p25nwr6d.cloudfront.net/CIK-0000040533/8a5193el-4ca4-4d33-b67d-dabb158e8ed9.pdf>. No other Crown family member is listed as controlling over 5% of the company's [REDACTED].
\ No newline at end of file
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diff --git a/marker2/court-pension-v-dimon/EFTA02823217/EFTA02823217.md b/marker2/court-pension-v-dimon/EFTA02823217/EFTA02823217.md
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+![](_page_0_Picture_1.jpeg)
+
+#### I United States District Court r Southern District of New York
+
+Ruby J. Krajick Clerk of Court
+
+Dear Litigant
+
+Enclosed is a copy of the judgment entered in your case. If you disagree with a judgment or final order of the district court, you may appeal to the United States Court of Appeals for the Second Circuit. To start this process, file a "Notice of Appeal" with this Court's Pro Se Intake Unit.
+
+You must file your notice of appeal in this Court within 30 days after the judgment or order that you wish to appeal is entered on the Court's docket, or, if the United States or its officer or agency is a party, within 60 days after entry of the judgment or order. If you are unable to file your notice of appeal within the required time, you may make a motion for extension of time, but you must do so within 60 days from the date of entry of the judgment, or within 90 days if the United States or its officer or agency is a party, and you must show excusable neglect or good cause for your inability to file the notice of appeal by the deadline.
+
+Please note that the notice of appeal is a one-page document containing your name, a description of the final order or judgment (or part thereof) being appealed, and the name of the court to which the appeal is taken (the Second Circuit) - it does not include your reasons or grounds for the appeal. Once your appeal is processed by the district court, your notice of appeal will be sent to the Court of Appeals and a Court of Appeals docket number will be assigned to your case. At that point, all further questions regarding your appeal must be directed to that court.
+
+The filing fee for a notice of appeal is \$605 payable in cash, by bank check, certified check, or money order, to "Clerk of Court, S.D.N.Y." No personal checks are accepted. Please see District Court fee schedule at https://www.nysd.uscourts.gov/programs/fees. If you are unable to pay the \$605 filing fee, complete the "Motion to Proceed in Forma Pauperis on Appeal" form and submit it with your notice of appeal to the Pro Se Intake Unit. If the district court denies your motion to proceed in forma pauperis on appeal, or has certified under 28 U.S.C. §1915(a)(3) that an appeal would not be taken in good faith, you may file a motion in the Court of Appeals for leave to appeal in forma pauperis, but you must do so within 30 days after service of the district court order that stated that you could not proceed in forma pauperis on appeal.
+
+For additional issues regarding the time for filing a notice of appeal, see Federal Rule of Appellate Procedure 4(a). There are many other steps to beginning and proceeding with your appeal, but they are governed by the rules of the Second Circuit Court of Appeals and the Federal Rules of Appellate Procedure. For more information, visit the Second Circuit Court of Appeals website at http://wonv.ca2.uscourts.gov/.
+
+THE DANIEL MOYNIHAN UNITED STATES COURTHOUSE SOO PEARL STREET New YORK. NY 10007.1312
+
+THE CHARLES L. BRIEANT, JR. UNITED STATES COURTHOUSE 300 QUARROPAS STREET PLAINS, NY 10601.4150
+
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+(List the full name(s) of the plaintiff(s)/petitioner(s).) CV
+
+-against-
+
+(List the full name(s) of the defendant(s)/respondent(s).)
+
+Notice is hereby given that the following parties:
+
+# NOTICE OF APPEAL
+
+)
+
+(list the names of all parties who are filing an appeal)
+
+in the above-named case appeal to the United States Court of Appeals for the Second Circuit
+
+from the ❑ judgment ❑ order entered on:
+
+(date that judgment or order was entered on docket)
+
+that:
+
+(If the appeal is from an order, provide a brief description above of the decision in the order.)
+
+Dated Signature.
+
+Name (last, First, MI)
+
+Address City State Zip Code
+
+Telephone Number E-mail Address (if available)
+
+Each party filing the appeal must date and sign the Notice of Appeal and provide his or her mailing address and telephone number, EXCEPT that a signer of a pro se notice of appeal may sign for his or her spouse and minor children if they are parties to the case. Fed. R. App. P. 3(c)(2). Attach additional sheets of paper as necessary.
+
+**UNITED STATES DISTRICT COURT  
+SOUTHERN DISTRICT OF NEW YORK**
+
+\_\_\_\_\_  
+(List the full name(s) of the plaintiff(s)/petitioner(s).)
+
+\_\_\_\_\_ CV\_\_\_\_\_ ( ) ( )
+
+-against-
+
+**MOTION FOR EXTENSION  
+OF TIME TO FILE NOTICE  
+OF APPEAL**
+
+\_\_\_\_\_  
+(List the full name(s) of the defendant(s)/respondent(s).)
+
+I move under Rule 4(a)(5) of the Federal Rules of Appellate Procedure for an extension of time to file a notice of appeal in this action. I would like to appeal the judgment entered in this action on \_\_\_\_\_ but did not file a notice of appeal within the required time period because:  
+\_\_\_\_\_  
+\_\_\_\_\_  
+\_\_\_\_\_
+
+(Explain here the excusable neglect or good cause that led to your failure to file a timely notice of appeal.)
+
+| _____<br>Dated:                        | <div style="background-color: red; border: 1px solid black; display: inline-block; padding: 2px;">██████████</div> _____<br>Signature |
+|----------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------|
+| _____<br>Name (Last, First, MI)        |                                                                                                                                       |
+| _____<br>Address                       |                                                                                                                                       |
+| _____<br>Telephone Number              |                                                                                                                                       |
+| _____<br>E-mail Address (if available) |                                                                                                                                       |
+
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+CV ( )( )
+
+(list the full name(s) of the plaintiff(s)/petitioner(s).)
+
+-against-
+
+(List the full name(s) of the defendant(s)/respondent(s).)
+
+### MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS ON APPEAL
+
+I move under Federal Rule of Appellate Procedure 24(a)(1) for leave to proceed in forma pauperis on appeal. This motion is supported by the attached affidavit.
+
+Dated Signature
+
+Name (Last, First, MI)
+
+Address City State Zip Code
+
+Telephone Number E-mail Address (if available)
+
+### Application to Appeal In Forma Pauperis
+
+v. Appeal No.
+
+District Court or Agency No.
+
+| <b>Affidavit in Support of Motion</b>                                                                                                                                                                                                                                                                                                                 | <b>Instructions</b>                                                                                                                                                                                                                                                                                                                                                             |
+|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| <p>I swear or affirm under penalty of perjury that, because of my poverty, I cannot prepay the docket fees of my appeal or post a bond for them. I believe I am entitled to redress. I swear or affirm under penalty of perjury under United States laws that my answers on this form are true and correct. (28 U.S.C. § 1746; 18 U.S.C. § 1621.)</p> | <p>Complete all questions in this application and then sign it. Do not leave any blanks: if the answer to a question is "0," "none," or "not applicable (N/A)," write that response. If you need more space to answer a question or to explain your answer, attach a separate sheet of paper identified with your name, your case's docket number, and the question number.</p> |
+| Signed: _____                                                                                                                                                                                                                                                                                                                                         | Date: _____                                                                                                                                                                                                                                                                                                                                                                     |
+
+My issues on appeal are: (required):
+
+- 1. For both you and your spouse estimate the average amount of money received from each of the following sources during the past 12 months. Adjust any amount that was received weekly, biweekly, quarterly, semiannually, or annually to show the monthly rate. Use gross amounts, that is, amounts before any deductions for taxes or otherwise.
+
+| Income source   | Average monthly |     |        |
+|-----------------|-----------------|-----|--------|
+|                 | You Spouse      | You | Spouse |
+| Employment      | \$ \$           | 5   | S      |
+| Self-employment | S S             | S   | S      |
+|                 | \$ \$           | 5   | 5      |
+
+| Interest and dividends              | S    | S    | \$   | \$   |
+|-------------------------------------|------|------|------|------|
+| Gifts                               | S    | S    | S    | S    |
+| Alimony                             | S    | S    | S    | S    |
+| Child support                       | S    | S    | S    | S    |
+|                                     | \$   | S    | \$   | S    |
+|                                     | \$   | S    | \$   | S    |
+| Unemployment payments               | S    | S    | S    | S    |
+| Public-assistance (such as welfare) | \$   | \$   | S    | S    |
+| Other (specify):                    | S    | \$   | 5    | 5    |
+| Total monthly income:               | \$ 0 | \$ 0 | \$ 0 | \$ 0 |
+
+- 2. List your employment history for the past two years, most recent employer first (Gross monthly pay is before taxes or other deductions.)
+
+| Employer | Address | Dates of employment | Gross monthly pay |
+|----------|---------|---------------------|-------------------|
+|          |         |                     | \$                |
+|          |         |                     | \$                |
+|          |         |                     | \$                |
+
+- 3. List your spouse's employment history for the past two years, most recent employer first. (Gross monthly pay is before taxes or other deductions.)
+
+| Employer | Address | Dates of employment | Gross monthly pay |
+|----------|---------|---------------------|-------------------|
+|          |         |                     | \$                |
+|          |         |                     | \$                |
+|          |         |                     | \$                |
+
+4. How much cash do you and your spouse have? \$
+
+Below, state any money you or your spouse have in bank accounts or in any other financial institution.
+
+| Financial Institution Type of Account Amount you have | Amount your |
+|-------------------------------------------------------|-------------|
+| S                                                     | \$          |
+| \$                                                    | \$          |
+| \$                                                    | \$          |
+
+If you are a prisoner seeking to appeal a judgment in a civil action or proceeding, you must attach a statement certified by the appropriate institutional officer showing all receipts, expenditures, and balances during the last six months in your institutional accounts. If you have multiple accounts, perhaps because you have been in multiple institutions, attach one certified statement of each account
+
+5. List the assets, and their values, which you own or your spouse owns. Do not list clothing and ordinary household furnishings.
+
+| Home       | Other real estate | Motor vehicle #1 |
+|------------|-------------------|------------------|
+| (Value) \$ | (Value) \$        | (Value) \$       |
+|            |                   | Make and year:   |
+|            |                   | Model:           |
+|            |                   | Registration #:  |
+
+| Motor vehicle #2 | Other assets | Other assets |
+|------------------|--------------|--------------|
+| (Value) \$       | (Value) \$   | (Value) \$   |
+| Make and year:   |              |              |
+| Model:           |              |              |
+| Registration #:  |              |              |
+
+- 6. State every person, business, or organization owing you or your spouse money, and the amount owed.
+
+| Amount owed to you | Amount owed to your |
+|--------------------|---------------------|
+| 5                  | \$                  |
+| S                  | \$                  |
+| S                  | \$                  |
+| \$                 | \$                  |
+
+- 7. State the persons who rely on you or your spouse for support.
+
+| Name [or, if a minor (i.e., underage), initials only] | Relationship | Age |
+|-------------------------------------------------------|--------------|-----|
+|                                                       |              |     |
+|                                                       |              |     |
+|                                                       |              |     |
+
+- 8. Estimate the average monthly expenses of you and your family. Show separately the amounts paid by your spouse. Adjust any payments that are made weekly, biweekly. quarterly, semiannually, or annually to show the monthly rate.
+
+|                                                                    | You Your Spouse |
+|--------------------------------------------------------------------|-----------------|
+| lot rented for                                                     | \$ \$           |
+| Yes No                                                             |                 |
+| Yes a No                                                           |                 |
+| Utilities (electricity, heating fuel, water, sewer, and telephone) | \$ \$           |
+| Home maintenance (repairs and upkeep)                              | \$ \$           |
+| Food                                                               | \$ \$           |
+| Clothing                                                           | \$ \$           |
+| Laundry and dry-cleaning                                           | \$ \$           |
+| Medical and dental expenses                                        | \$ \$           |
+
+| Transportation (not including motor vehicle payments)  | \$   | S    |
+|--------------------------------------------------------|------|------|
+| Recreation, entertainment, newspapers, magazines, etc. | \$   | \$   |
+|                                                        | \$   | \$   |
+|                                                        | \$   | \$   |
+|                                                        | \$   | \$   |
+|                                                        | \$   | \$   |
+|                                                        | \$   | \$   |
+|                                                        | \$   | \$   |
+|                                                        | S    | S    |
+|                                                        | S    | S    |
+|                                                        | S    | S    |
+| Alimony, maintenance, and support paid to others       | \$   | \$   |
+|                                                        | \$   | \$   |
+| Other (specify):                                       | \$   | \$   |
+| Total monthly expenses:                                | \$ 0 | \$ 0 |
+
+- 9. Do you expect any major changes to your monthly income or expenses or in your assets or liabilities during the next 12 months?
+
+Yes ❑ No If yes, describe on an attached sheet.
+
+- 10. Have you spent or will you be spendin d —any money for expenses or attorney fees in connection with this lawsuit? Yes No
+
+If yes, how much? \$
+
+- II. Provide any other information that will help explain why you cannot pay the docket fees for your appeal.
+
+- 12. Identify the city and state of your legal residence.
+
+City State
+
+Your daytime phone number.
+
+Your age: Your years of schooling:
+
+Last four digits of your social-security number:
\ No newline at end of file
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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+CITY OF MIAMI GENERAL EMPLOYEES & SANITATION EMPLOYEES RETIREMENT TRUST and OPERATING ENGINEERS CONSTRUCTION INDUSTRY AND MISCELLANEOUS PENSION FUND
+
+Plaintiff, 23 CIVIL 3903(JSR)
+
+-against-
+
+JAMES DIMON, STEPHEN,. TODD A. COMBS, JAMES S. CROWN, TIMOTHY P. FLYNN, MELLODY HOBSON, JOHN W. KESSLER, PHEBE N. NOVAKOVIC, and JAMES E. STALEY,
+
+Defendants.
+
+## JUDGMENT
+
+It is hereby ORDERED, ADJUDGED AND DECREED: That for the reasons stated in the Court's Opinion and Order dated January 12, 2024, the Court grants the motions to dismiss. Because the plaintiffs have already amended their complaint and because, even based on the additional allegations referenced in their reply papers, the complaint would still have to be dismissed, the dismissal is with prejudice. Accordingly, the Court hereby dismisses the case with prejudice and closes the case.
+
+Dated: New York, New York
+
+January 12, 2024 RUBY J. KRAJICK Clerk of Court
+
+BY:
+
+Deputy Clerk
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