MEMY-1805 harvest: vision-fixhub (part 29)

vision-fixhub/court-05/c71d740632db0a930c938dde436663122d7b2b287d1083cddfc4bfbede3e9a80.md

@@ -0,0 +1,24 @@
+Case 1:22-cV-10904-JSR Document 265-30 Filed 08/07/23 Page 1 of 2
+
+
+
+From:
+To:
+Sent:
+Subject:
+Case 1:22-cv-10904-JSR Document 265-30 Filed 08/07/23 Page 2 of 2
+Jes Staley <jes.staley@jpmorgan.com>
+"jeevacation@gmail.com' <jeevacation@gmail.com>
+11/1/2009 1:37:54 PM
+So when all hell breaks lose, 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.
+Best
+Jes
+
+JPM-SDNYLIT-00006592

vision-fixhub/court-05/c71d740632db0a930c938dde436663122d7b2b287d1083cddfc4bfbede3e9a80.receipt.json

@@ -0,0 +1,14 @@
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vision-fixhub/court-05/c72adc6536eb24c1dc345abd9506c205a92659794a1a6f7b9a7f6ae1dba320bf.md

@@ -0,0 +1,463 @@
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 1 of 18
+IN THE UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF NEW YORK
+GOVERNMENT OF THE UNITED
+STATES VIRGIN ISLANDS,
+Plaintiff,
+V.
+JP/
+Case No. 22-cv-10904 (JSR)
+CHASE BANK, N.A.,
+Defendant.
+DECLARATION OF FELICIA H. ELLSWORTH
+IN SUPPORT OF JPMORGAN CHASE BANK, N.A.'S OPPOSITION TO
+USVI'S MOTION TO STRIKE AFFIRMATIVE DEFENSES
+Pursuant to 28 U.S.C. § 1746, 1, Felicia H. Ellsworth, declare under penalty of perjury as
+follows:
+I am a member in good standing of the bar of the Commonwealth of Massachusetts. I
+am one of the attorneys representing Defendant JPMorgan Chase Bank, N.A.
+("JPMC"") in the above-captioned action and have been admitted to this Court pro hac
+vice. I am a Partner with the law firm of Wilmer Cutler Pickering Hale and Dorr
+LLP, 60 State Street, Boston, Massachusetts 02109. I am familiar with the facts set
+forth herein, and if called as a witness, I could and would competently testify thereto.
+2.
+Attached as Exhibit 1 is a true and correct copy of a document produced by the Estate
+of Jeffrey Epstein,
+stamped ESTATE_JPM020484, designated confidential
+pursuant to the Protective Order in this matter and filed under seal.
+3.
+Attached as Exhibit 2 is a true and correct copy of a document produced by the Estate
+of Jeffrey Epstein,
+stamped ESTATE_JPM015326, designated confidential
+pursuant to the Protective Order in this matter and filed under seal.
+1
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 2 of 18
+4. Attached as Exhibit 3 is a true and correct copy of a document produced by the Estate
+of Jeffrey Epstein, stamped ESTATE_JPM015321, designated confidential
+pursuant to the Protective Order in this matter and filed under seal.
+5. Attached as Exhibit 4 is a true and correct copy of an article titled "Former DPNR
+6.
+8.
+9.
+Commissioner says territory must learn from Epstein's legacy," dated February 18,
+2020, available at http://www.virginislandsdailynews.com/news/former-dpnrcommissioner-says-territory-must-learn-from-epsteins-legacy/article_cedat725-3eeb-
+5cf7-8499-09b4c0e37eae.html.
+Attached as Exhibit 5 is a true and correct copy of an article titled "Jeffrey Epstein's
+donations to young pupils prompts US Virgin Islands review," dated January 13,
+2015, available at https://www.theguardian.com/us-news/2015/jan/13/jeffrey-epsteindonations-us-virgin-islands-review.
+Attached as Exhibit 6 is a true and correct copy of a document produced by the Estate
+of Jeffrey Epstein,
+stamped ESTATE_JPM016517, designated confidential
+pursuant to the Protective Order in this matter and filed under seal.
+Attached as Exhibit 7 is a true and correct copy of a document produced by the Estate
+of Jeffrey Epstein,
+stamped ESTATE_JPM016246, designated confidential
+pursuant to the Protective Order in this matter and filed under seal.
+Attached as Exhibit 8 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000006066, designated confidential pursuant to the Protective Order in this matter and
+10. Attached as Exhibit 9 is a true and correct copy of a document produced by the Estate
+of Jeffrey Epstein,
+stamped ESTATE_JPM025237, designated confidential
+pursuant to the Protective Order in this matter and filed under seal.
+2
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 3 of 18
+11. Attached as Exhibit 10 is a true and correct copy of excerpts of the transcript of the
+May 9, 2023 deposition of Stacey E. Plaskett.
+12. Attached as Exhibit 11 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, L
+stamped ESTATE_JPM012219, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+13. Attached as Exhibit 12 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, C
+stamped ESTATE_JPM015885, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+14. Attached as Exhibit 13 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, L
+stamped ESTATE_JPM015674, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+15. Attached as Exhibit 14 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM016163, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+16. Attached as Exhibit 15 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM015950, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+17. Attached as Exhibit 16 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM012505, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+18. Attached as Exhibit 17 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM015733, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+3
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 4 of 18
+19. Attached as Exhibit 18 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM016245, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+20. Attached as Exhibit 19 is a true and correct copy of an article titled "V.I. files lawsuit
+against JP
+in Epstein case while ignoring local pols who benefited," dated
+February 14, 2023, available at http://www.virginislandsdailynews.com/opinion/v-i-
+files-lawsuit-against-jp-l
+-in-epstein-case-while-ignoring-local-polswho/article_17b3cbb1-448b-52b4-a19a-d1b62d7f44d6.html.
+21. Attached as Exhibit 20 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM016303, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+22. Attached as Exhibit 21 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM015672, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+23. Attached as Exhibit 22 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM024203, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+24. Attached as Exhibit 23 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM024371, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+25. Attached as Exhibit 24 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM024927, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+4
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 5 of 18
+26. Attached as Exhibit 25 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM024548, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+27. Attached as Exhibit 26 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM024549, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+28. Attached as Exhibit 27 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, L
+(stamped ESTATE_JPM022970, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+29. Attached as Exhibit 28 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, [
+stamped ESTATE_JPM016210, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+30. Attached as Exhibit 29 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, [
+stamped ESTATE_JPM015655, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+31. Attached as Exhibit 30 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM015854, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+32. Attached as Exhibit 31 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, |
+stamped ESTATE_JPM021989, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+33. Attached as Exhibit 32 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM023608, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+5
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 6 of 18
+34. Attached as Exhibit 33 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM022393, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+35. Attached as Exhibit 34 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM016066, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+36. Attached as Exhibit 35 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, [
+stamped ESTATE_JPM022997, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+37. Attached as Exhibit 36 is a true and correct copy of an article titled "Epstein estate
+could be ordered to repay more than $144 million in tax breaks," dated February 13,
+2020, available at http://www.virginislandsdailynews.com/news/epstein-estate-couldbe-ordered-to-repay-more-than-144-million-in-tax-breaks/article_b84d9710-14af-
+5e69-a890-bcf8265cf8f9.html.
+38. Attached as Exhibit 37 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000019063, designated confidential pursuant to the Protective Order in this matter and
+39. Attached as Exhibit 38 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000017983, designated confidential pursuant to the Protective Order in this matter and
+40. Attached as Exhibit 39 is a true and correct copy of a document produced by Plaintiff
+6
+
+
+Case 1:22-CV-10904-JSR Document 158 Filed 05/23/23 Page 7 of 18
+000012922, designated confidential pursuant to the Protective Order in this matter and
+41. Attached as Exhibit 40 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000012885, designated confidential pursuant to the Protective Order in this matter and
+42. Attached as Exhibit 41 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000012850, designated confidential pursuant to the Protective Order in this matter and
+43. Attached as Exhibit 42 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000012816, designated confidential pursuant to the Protective Order in this matter and
+44. Attached as Exhibit 43 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000012722, designated confidential pursuant to the Protective Order in this matter and
+45. Attached as Exhibit 44 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000012689, designated confidential pursuant to the Protective Order in this matter and
+46. Attached as Exhibit 45 is a true and correct copy of a document produced by Plaintiff
+
+
+Case 1:22-CV-10904-JSR Document 158 Filed 05/23/23 Page 8 of 18
+000012630, designated confidential pursuant to the Protective Order in this matter and
+47. Attached as Exhibit 46 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000012940, designated confidential pursuant to the Protective Order in this matter and
+48. Attached as Exhibit 47 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000012743, designated confidential pursuant to the Protective Order in this matter and
+49. Attached as Exhibit 48 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000013335, designated confidential pursuant to the Protective Order in this matter and
+50. Attached as Exhibit 49 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000013219, designated confidential pursuant to the Protective Order in this matter and
+51. Attached as Exhibit 50 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000013122, designated confidential pursuant to the Protective Order in this matter and
+52. Attached as Exhibit 51 is a true and correct copy of a document produced by Plaintiff
+8
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 9 of 18
+000013087, designated confidential pursuant to the Protective Order in this matter and
+53. Attached as Exhibit 52 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000012996, designated confidential pursuant to the Protective Order in this matter and
+54. Attached as Exhibit 53 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000018005, designated confidential pursuant to the Protective Order in this matter and
+55. Attached as Exhibit 54 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000007315, designated confidential pursuant to the Protective Order in this matter and
+56. Attached as Exhibit 55 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000007407, designated confidential pursuant to the Protective Order in this matter and
+57. Attached as Exhibit 56 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000007474, designated confidential pursuant to the Protective Order in this matter and
+58. Attached as Exhibit 57 is a true and correct copy of a document produced by Plaintiff
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 10 of 18
+000007534, designated confidential pursuant to the Protective Order in this matter and
+59. Attached as Exhibit 58 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000007588, designated confidential pursuant to the Protective Order in this matter and
+60. Attached as Exhibit 59 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000007663, designated confidential pursuant to the Protective Order in this matter and
+61. Attached as Exhibit 60 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000013479, designated confidential pursuant to the Protective Order in this matter and
+62. Attached as Exhibit 61 is a true and correct copy of a document produced by Marks
+Paneth LLP and reproduced by Plaintiff the Government of the United States Virgin
+Islands,
+stamped MP-00001858, designated confidential pursuant to the
+Protective Order in this matter and filed under seal.
+63. Attached as Exhibit 62 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000023078, designated confidential pursuant to the Protective Order in this matter and
+64. Attached as Exhibit 63 is a true and correct copy of a document produced by Plaintiff
+10
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 11 of 18
+000023091, designated confidential pursuant to the Protective Order in this matter and
+65. Attached as Exhibit 64 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, [
+(stamped ESTATE_JPMO11964, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+66. Attached as Exhibit 65 is a true and correct copy of excerpts of the transcript of the
+May 17, 2023 deposition of Sandra Bess, designated confidential pursuant to the
+Protective Order in this matter and filed under seal.
+67. Attached as Exhibit 66 is a true and correct copy of a document produced by the
+stamped ESTATE_JPMO15014, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+68. Attached as Exhibit 67 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000022897, designated confidential pursuant to the Protective Order in this matter and
+69. Attached as Exhibit 68 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000016206, designated confidential pursuant to the Protective Order in this matter and
+70. Attached as Exhibit 69 is a true and correct copy of an article titled "Jeffrey Epstein
+case threatens to drag Virgin Islands elite into the muck. Will it matter?," dated
+February 14, 2020, available at https://www.miamiherald.com/news/nationworld/world/americas/article240300016.html.
+11
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 12 of 18
+71. Attached as Exhibit 70 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, L
+stamped ESTATE_JPM018432, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+72. Attached as Exhibit 71 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000017233, designated confidential pursuant to the Protective Order in this matter and
+73. Attached as Exhibit 72 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000016492, designated confidential pursuant to the Protective Order in this matter and
+74. Attached as Exhibit 73 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM016160, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+75. Attached as Exhibit 74 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM019854, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+76. Attached as Exhibit 75 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM022238, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+77. Attached as Exhibit 76 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000064950, designated confidential pursuant to the Protective Order in this matter and
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 13 of 18
+78. Attached as Exhibit 77 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM024492, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+79. Attached as Exhibit 78 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM025219, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+80. Attached as Exhibit 79 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, |
+stamped ESTATE_JPM016427, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+81. Attached as Exhibit 80 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, |
+stamped ESTATE_JPM025221, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+82. Attached as Exhibit 81 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, |
+stamped ESTATE_JPM025227, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+83. Attached as Exhibit 82 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000012237, designated confidential pursuant to the Protective Order in this matter and
+84. Attached as Exhibit 83 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000012446, designated confidential pursuant to the Protective Order in this matter and
+85. Attached as Exhibit 84 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+13
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 14 of 18
+000087823, designated confidential pursuant to the Protective Order in this matter and
+86. Attached as Exhibit 85 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000012395, designated confidential pursuant to the Protective Order in this matter and
+87. Attached as Exhibit 86 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000012328, designated confidential pursuant to the Protective Order in this matter and
+88. Attached as Exhibit 87 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000088062, designated confidential pursuant to the Protective Order in this matter and
+89. Attached as Exhibit 88 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000088093, designated confidential pursuant to the Protective Order in this matter and
+90. Attached as Exhibit 89 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000086731, designated confidential pursuant to the Protective Order in this matter and
+91. Attached as Exhibit 90 is a true and correct copy of a document produced by Plaintiff
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 15 of 18
+000086752, designated confidential pursuant to the Protective Order in this matter and
+92. Attached as Exhibit 91 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000087016, designated confidential pursuant to the Protective Order in this matter and
+93. Attached as Exhibit 92 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000064833, designated confidential pursuant to the Protective Order in this matter and
+94. Attached as Exhibit 93 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000080855, designated confidential pursuant to the Protective Order in this matter and
+95. Attached as Exhibit 94 is a true and correct copy of a document produced by Plaintiff
+the Government of the United States Virgin Islands,
+000012616, designated confidential pursuant to the Protective Order in this matter and
+96. Attached as Exhibit 95 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, |
+stamped ESTATE_JPM025196, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+97. Attached as Exhibit 96 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM024114, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 16 of 18
+98. Attached as Exhibit 97 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM020206, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+99. Attached as Exhibit 98 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM024119, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+100. Attached as Exhibit 99 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, L
+stamped ESTATE_JPM024130, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+101. Attached as Exhibit 100 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, L
+(stamped ESTATE_JPM020983, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+102. Attached as Exhibit 101 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, L
+stamped ESTATE_JPM023450, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+103. Attached as Exhibit 102 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, |
+stamped ESTATE_JPM021434, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+104. Attached as Exhibit 103 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, |
+stamped ESTATE_JPM015784, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+105. Attached as Exhibit 104 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM015122, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 17 of 18
+106. Attached as Exhibit 105 is a true and correct copy of an article titled "Where Is
+Jeffrey Epstein's Money Going?," dated January 28, 2022, available at
+https://www.nytimes.com/2022/01/28/business/jeffrey-epsteinestate.html#:~;text=The%20estate%20has%20paid%20%249,Court%20in%20the%20
+Virgin%20Islands.
+107. Attached as Exhibit 106 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM023269, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+108. Attached as Exhibit 107 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM016129, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+109. Attached as Exhibit 108 is a true and correct copy of an article titled "The Girls Were
+Just So Young': The Horrors of Jeffrey Epstein's Private Island," dated July 20, 2019,
+available at https://www.vanityfair.com/news/2019/07/horrors-of-jeffrey-epsteinprivate-island.
+110. Attached as Exhibit 109 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM015782, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+111. Attached as Exhibit 110 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, |
+stamped ESTATE_JPM016521, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+112. Attached as Exhibit I11 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM024879, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+
+
+Case 1:22-cv-10904-JSR Document 158 Filed 05/23/23 Page 18 of 18
+113. Attached as Exhibit 112 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM016458, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+114. Attached as Exhibit 113 is a true and correct copy of a document produced by the
+stamped ESTATE_JPM025693, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+115. Attached as Exhibit 114 is a true and correct copy of a document produced by the
+Estate of Jeffrey Epstein, L
+stamped ESTATE_JPM022234, designated
+confidential pursuant to the Protective Order in this matter and filed under seal.
+Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is
+true and correct.
+Dated: May 23, 2023
+/s/ Felicia Ellsworth
+Felicia H. Ellsworth
+18

vision-fixhub/court-05/c72adc6536eb24c1dc345abd9506c205a92659794a1a6f7b9a7f6ae1dba320bf.receipt.json

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vision-fixhub/court-05/c73e760b240d691c80061b4edd2ee3c0483df0d32fbac92457091528d74dffc0.md

@@ -0,0 +1,372 @@
+Case 1:22-cv-10904-JSR Document 326-1 Filed 09/08/23 Page 1 of 7
+
+
+
+1
+Case 1:28fM 10A₩§B1 Down 339₺ Eid 0908₴3t Page Beaer
+UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF NEW YORK
+GOVERNMENT OF THE UNITED
+STATES VIRGIN ISLANDS
+Plaintiff,
+3
+4
+5 VS.
+6
+1:22-CV-10904-JSR
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+JPMORGAN CHASE BANK, N.A.,
+Defendant/Third-
+Party Plaintiff.
+JPMORGAN CHASE BANK, N.A.
+Third-Party
+Plaintiff,
+VS.
+JAMES EDWARD STALEY,
+Third-Party
+Defendant.
+SATURDAY, JUNE 10, 2023
+CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER
+- —
+-
+Videotaped deposition of James E.
+Staley, held at the offices of Boies Schiller
+Flexner, LLC, 55 Hudson Yards, New York, New
+York,
+commencing at 9:13 a.m. Eastern, on the
+above date, before Carrie A.
+Registered Diplomate Reporter and Certified
+Realtime Reporter.
+-
+GOLKOW LITIGATION SERVICES
+877.370.3377 ph | 917.591.5672 fax
+deps@golkow.com
+Page 1
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+Mid-'90s.
+Q.
+And do you recall that Jeffrey
+Epstein served as Les Wexner's money manager?
+A.
+I recall that Epstein was an
+advisor to Les Wexner. I don't know in what
+capacity.
+And do you know if Jamie Dimon
+and Les Wexner knew one another?
+A.
+I imagine they did, yes.
+Have you ever met Les Wexner?
+A.
+Yes.
+e.
+In what context?
+A.
+Taking The Limited public.
+That was before Mr. Dimon
+joined the company, correct?
+A.
+Yes.
+And when you took The Limited
+public in the mid-'90s, you hadn't met
+Jeffrey Epstein as part of that; is that
+fair?
+A.
+My recollection is that's the
+first time that I met him.
+l.
+So you believe you met him at
+some point before Sandy Warner suggested that
+you have a meeting with him; is that correct?
+Page 54
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:ZofM}09ºAt§R1 Doсш093art Eld0908£3t Page beter
+A.
+Very briefly, yes.
+Q.
+And that would have been in
+relation to taking The Limited public?
+A.
+I was visiting The Limited, and
+my recollection is Epstein had an office
+there, and I saw him for a couple minutes.
+And is it fair at that time you
+would -- you didn't know who he was?
+A.
+No.
+Why would you imagine that
+Jamie Dimon and Les Wexner knew one another?
+A.
+Both their involvements with
+Ohio.
+e.
+What is Jamie Dimon's
+involvement with Ohio?
+A.
+I think he worked for the bank
+there.
+e.
+Did you have occasion to meet
+with Les Wexner after 2000?
+A.
+Not that I recall.
+e.
+I want to talk about Labe
+A.
+e.
+Do you know who that is?
+Uh-huh, yes, I do.
+And how do you know Labe
+Page 55
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:20101045R1 00009*339 d090863t Page beder
+don't know.
+Q.
+Irrespective of your
+involvement with his accounts, the fact that
+he had his accounts and the size of his
+accounts at JPMorgan benefitted JPMorgan.
+You would agree, right?
+A.
+I think no -- you know, I don't
+think any single client is that important,
+but he was a client of the bank.
+And he continued to refer
+clients to JPMorgan before, during and after
+his incarceration, correct?
+MR. GAIL: Objection.
+THE WITNESS: I don't think he
+referred clients to the bank. I met
+clients through him, but I don't think
+he was making a referral.
+QUESTIONS BY MR.
+Do you know who
+McGraw
+is?
+A.
+No.
+Do you remember a Tom McGraw in
+the tax department of JPMorgan?
+A.
+I don't.
+Did you ever become aware of
+Page 386
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+e.
+Did you ever cooperate in any
+of the investigations, like voluntarily
+cooperate in any of the investigations, into
+Jeffrey Epstein?
+No.
+Q.
+Do you know whether JPMorgan
+cooperated in the Florida investigation,
+either on the state level or the federal
+level, in the 2006 to 2008 time frame?
+A.
+I don't know.
+e.
+Were you ever asked whether
+JPMorgan should cooperate in that
+investigation?
+A.
+Not that I recall.
+e.
+After Jeffrey Epstein was
+arrested, did you go visit him?
+A.
+When?
+e.
+When he was arrested, sorry, in
+2019.
+A.
+No, I did not.
+Q.
+When was the last time you
+spoke with Jeffrey Epstein?
+A.
+I want to say October,
+November 2015.
+Q.
+Why was that the last time that
+Page 393
+
+
+Case 1:ZofM100AW§R1 Doc09533ft Etd0908Zet Page beter
+1
+you spoke with Jeffrey Epstein?
+2
+A.
+I became CEO of Barclays.
+3
+e.
+And what about your position as
+4
+CEO of Barclays had anything to do with you
+5
+no longer meeting with or communicating with
+6
+Jeffrey Epstein?
+7
+A.
+Being CEO of a major British
+bank is a very, very visible job, and I
+9 thought it was not appropriate to deal at all
+10
+with Epstein in that role.
+11
+12
+l.
+By that point in time, did you
+realize that Jeffrey Epstein had lied to you
+13
+in the past about his lack of understanding
+14
+15
+of the ages of some of the victims that had
+accused him?
+16
+A.
+Yes.
+17
+18
+19
+20
+21
+22
+23
+e.
+And did that have anything to
+do with your making a decision to stop
+talking with him?
+A.
+Yeah. I think it became
+increasingly that he had a very, very
+terrible past, and I didn't want to be
+associated with him.
+24
+25
+When you were CEO of Barclays,
+did you remain in contact with Prince Andrew?
+Page 394

vision-fixhub/court-05/c73e760b240d691c80061b4edd2ee3c0483df0d32fbac92457091528d74dffc0.receipt.json

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vision-fixhub/court-05/c7579b098e29ceeeace10a3416991b17fefcc346d13f38bf57e1e39a96f4d31e.md

@@ -0,0 +1,58 @@
+Case 1:22-cv-10904-JSR Document 226-1 Filed 07/24/23 Page 1 of 3
+
+PART 1
+
+
+7/21/23, 12:18 PM
+The New Work Cimes https://www.nytimes.com/2019/08/28/business/jeffrey-epstein-island.html
+Epstein's Island, 'Little St. Jeff's': A Hideaway Where Money Bought Influence
+By Steve Eder
+Aug. 28, 2019
+ST.
+. V.I. — Jeffrey Epstein once described the United States Virgin Islands as "my favorite place to be."
+When he was there, Mr. Epstein had a knack for getting his way, according to public records and interviews with residents and local
+officials.
+Mr. Epstein, the accused sex trafficker who committed suicide in a Manhattan jail this month, used these islands as a personal and
+corporate hideaway, negotiating lucrative local tax breaks even as he faced federal investigations for sexual misconduct.
+He cultivated close ties to the islands' political and financial elite. He employed a governor's wife. He hired an architecture firm owned by
+that governor's uncle. He donated money, sponsored scholarships and even gave dozens of computers to a local lawmaker to distribute.
+The islands became a haven for Mr. Epstein. His private plane would fly him to St.
+international airport, where he would board a
+helicopter that whisked him to his Little St. James and Great St. James islands. Once there, he was known to entertain famous friends and,
+his accusers have said in court filings, traffic underage girls for sex.
+While federal authorities spent years criminally investigating Mr. Epstein, a spokesman for the local police department said it had no
+records of having visited his Virgin Islands properties.
+"It was kind of accepted," said Sasha Bouis, who used to run a floating restaurant anchored near Great St. James. "There was just this
+creepy old billionaire living out there."
+Mr. Epstein's mansion on Little St. James. He paid $7.95 million for Little St. James in 1998 and spent millions more developing his two islands. Gabriel
+Albarran/Associated Press
+https://www.nytimes.com/2019/08/28/business/jeffrey-epstein-island.html
+1/4
+
+
+7/21/23, 12:18 PM Case 1:22-C7p10004dSBttleDoenent226, IhefelladleD Edish/ 2 BuerBage Breaf YBrk Times
+Since Mr. Epstein was charged with sex trafficking in July, his island operations have been under scrutiny. A few days after his Aug. 10
+death, F.B.I. agents and New York Police Department investigators raided Little St. James, which some locals say they had nicknamed
+"Pedophile Island."
+Federal prosecutors handling Mr. Epstein's sex-trafficking case have said the investigation will not end with his death. In recent lawsuits,
+his accusers have lodged fresh claims about how they were sexually assaulted on his islands.
+In the weeks ahead, the wrangling over Mr. Epstein's assets is likely to play out on St. |
+estate filed his will in court on St.
+and said he had more than $570 million in assets.
+|. Last week, lawyers handling Mr. Epstein's
+Mr. Epstein arrived in the Virgin Islands in 1998, when he paid $7.95 million for Little St. James, a roughly 70-acre island. Mr. Epstein
+called it "Little St. Jeff's." In 2016, he bought the larger Great St. James for $17.5 million.
+Over the years, he spent millions more developing the islands, including building a villa with a library, a Japanese bathhouse and a movie
+theater.
+His construction projects led to repeated clashes between Mr. Epstein and the Virgin Islands Department of Planning and Natural
+Resources, according to paperwork related to his work permits reviewed by The New York Times.
+A memo from the agency's wildlife chief in 2010 noted that Mr. Epstein's properties had "a long history of egregious and blatant disregard
+for environmental regulations." Projects had "introduced several nonnative species to the island." The arrival of one invasive species, the
+Cuban tree frog, led to a recommendation that all landscaping and building materials be inspected, the memo said.
+Mr. Epstein called Little St. James Island "Little St. Jeff's." Gabriella N. Baez for The New York Times
+Mr. Epstein's lawyers resolved some disputes by paying fines, retroactively applying for permits and making donations, sometimes using
+funds from his charities.
+In 2016, Mr. Epstein reached a settlement with the agency over unapproved construction projects on Great St. James. Officials soon
+accused his company of violating the agreement by not removing a beach bar cabana and by expanding a driveway, despite a stop-work
+https://www.nytimes.com/2019/08/28/business/jeffrey-epstein-island.html
+2/4

vision-fixhub/court-05/c7579b098e29ceeeace10a3416991b17fefcc346d13f38bf57e1e39a96f4d31e.receipt.json

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+}

vision-fixhub/court-05/c764a83c746666613a9898793a6cb91a1e92b1eeab04e563b26db84291d3985e.md

@@ -0,0 +1,160 @@
+Case 1:22-cV-10904-JSR Document 243-24 Filed 07/25/23 Page 1 of 8
+
+
+
+Case 1:22-cV-10904-JSR Document 243-24 Filed 07/25/23 Page 2 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+CASE NO.: 1:22-cv-10019 (JSR)
+ane Doe 1, Individually and on bea
+of all others similarly situated
+Plaintiff,
+VS.
+JPMorgan Chase Bank, N.A.,
+Defendant.
+/
+JPMORGAN CHASE BANK, N.A.'S SUPPLEMENTAL RESPONSES AND
+OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES
+Pursuant to Federal Rules of Civil Procedure 26 and 33, Defendant JPMorgan Chase Bank,
+N.A. ("JPMC"") raises the following objections and provides the following responses to Plaintiff's
+First Set of Interrogatories, based on information reasonably available to JPMC at this time without
+prejudice to JPMC's right to revise, supplement, or amend these objections and responses in
+accordance with Rules 26 and 33.
+PRELIMINARY STATEMENT
+These objections and responses are made solely for the purposes of the above-captioned
+case. Each of JPMC's objections and responses to Plaintiff's Interrogatories is based on
+information and documents presently available to JPMC after reasonable inquiry. Discovery is
+ongoing, and JPMC specifically reserves the right to amend or supplement these objections and
+responses as necessary, including in the event further information and documents are discovered
+or produced by JPMC after discovery has been completed. In addition, JPMC's objections and
+
+
+Case 1:22-cv-10904-JSR Document 243-24 Filed 07/25/23 Page 3 of 8
+responses are given without prejudice to its rights to introduce at trial evidence of any subsequently
+discovered or unintentionally omitted facts or documents.
+To the extent JPMC responds to a specific interrogatory below, JPMC does not admit to
+Plaintiff's characterization of any documents, facts, theories, or conclusions. JPMC's responses
+to the Interrogatories do not constitute acquiescence or agreement to any definition proposed by
+Plaintiff. JPMC's objections and responses are made without in any way waiving or intending to
+waive, but to the contrary, are intended to preserve:
+All questions as to competency, relevancy, materiality, privilege, and admissibility
+as evidence for any purpose of the responses or subject matter thereof, in this action or any
+subsequent proceeding associated with this action or any other matter;
+The right to object on any ground to the use of said responses, or the subject matter
+thereof, in any subsequent proceeding associated with this action or any other matter; and
+3.
+The right to object at any time to other requests or other discovery procedures
+involving or relating to the subject matter of these Interrogatories.
+GENERAL OBJECTIONS
+JPMC incorporates by reference the General Objections asserted in JPMorgan
+Chase Bank, N.A.'s Responses and Objections to Plaintiff's First Set of Interrogatories served on
+February 1, 2023.
+1.
+OBJECTIONS TO DEFINITIONS
+JPMC incorporates by reference the Objections to definitions asserted in JPMorgan
+Chase Bank, N.A.'s Responses and Objections to Plaintiff's First Set of Interrogatories served on
+February 1, 2023.
+- 2-
+
+
+Case 1:22-cV-10904-JSR Document 243-24 Filed 07/25/23 Page 4 of 8
+DocuSign Envelope ID: 0DF87429-4795-4B46-9AC2-F315AE798DCA
+SPECIFIC RESPONSES
+INTERROGATORY NO. 3
+List any high net-worth clients or businesses the introduction or relationship between that
+person or entity of which was facilitated by Jeffrey Epstein.
+RESPONSE TO INTERROGATORY NO. 3
+In addition to and specifically incorporating its foregoing General Objections and
+Objections to Definitions, JPMC objects to Interrogatory No. 3 because it would be more
+convenient, less burdensome, and less expensive to obtain the identity of individuals at JPMC
+through requests for production under Rule 34. Fed. R. Civ. P. 26(b)(2)(C)(i). JPMC also objects
+to Interrogatory No. 3 because the terms "high net worth," "introduction," "facilitated," and
+"relationship" are vague and ambiguous.
+Subject to and without waiving its objections, and based upon a reasonable and diligent
+investigation, JPMC states that Mr. Epstein had some involvement in the establishment of
+customer relationships between JPMC's private bank and Ghislaine Maxwell and Kathryn
+Ruemmier. If JPMC learns of others, it will supplement this answer.
+INTERROGATORY NO.4
+Identify all JPMorgan officers and employees with knowledge of information relevant to
+whether JPMorgan made any changes to policies, procedures, protocols, or practices as a
+consequence of its relationship with Jeffrey Epstein and/or any Epstein-related individual and
+entity or any public or negative attention it received due to those relationships.
+RESPONSE TO INTERROGATORY NO. 4
+In addition to and specifically incorporating its foregoing General Objections and
+Objections to Definitions, JPMC objects to Interrogatory No. 4 on the grounds that it is overly
+broad, unduly burdensome, and seeks information that is not relevant to any party's claims or
+defenses. Fed. R. Civ. P. 26(b)(I). JPMC also objects to Interrogatory No. 4 because it seeks
+information that can be obtained from a more convenient, less burdensome, or less expensive
+- 3 -
+
+
+Case 1:22-cv-10904-JSR Document 243-24 Filed 07/25/23 Page 5 of 8
+source, such as requests for production of documents under Rule 34 or depositions under Rule
+30(b)(1). Fed. R. Civ. P. 26(b)(2)(C)(i). JPMC further objects to Interrogatory No. 4 because the
+phrases "information relevant to whether JPMC made changes," and "as a consequence of its
+relationship" and "public or negative attention" are vague and ambiguous.
+Subject to and without waiving its objections, and based upon a reasonable and diligent
+investigation, JPMC did not make any changes to policies, procedures, protocols, or practices
+during the period from 1998 to 2019 as a consequence of its relationship with Jeffrey Epstein
+and/or any Epstein-related individual or entity, or any public or negative attention it received due
+to those relationships.
+Dated: April 11, 2023
+Respectfully submitted,
+By: Jolen Butts
+M.
+Robert L. Boone
+Hillary Chutter-Ames
+7 World Trade Center
+250 Greenwich Street
+New York, NY 10007
+(t) (212) 230-8800
+0212230-3338
+robert.boone@wilmerhale.com
+hillary.chutter-ames@wilmerhale.com
+Felicia H. Ellsworth
+John J. Butts
+60 State Street
+Boston,
+02109
+(t) (617) 526-6687
+(F (617) 526-5000
+felicia.ellsworth@wilmerhale.com
+john.butts@wilmerhale.com
+-4-
+
+
+Case 1:22-cV-10904-JSR Document 243-24 Filed 07/25/23 Page 6 of 8
+Attorneys for Defendant JPMorgan Chase Bank,
+N.A.
+- 5-
+
+
+Case 1:22-cV-10904-JSR Document 243-24 Filed 07/25/23 Page 7 of 8
+VERIFICATION OF INTERROGATORY ANSWERS
+I, Francis J. Pearn, state that, based on reasonable inquiry, including a review of documents
+and information provided by other employees of JPMorgan Chase Bank, N.A. and counsel, the
+foregoing answers are true and correct to the best of my knowledge, information, and belief.
+I verify under penalty of perjury that the foregoing is true and correct.
+DATED:
+April 11, 2023
+New York, NY
+Francis J. Pearn
+By:_
+Francis J. Pearn
+- 6-
+
+
+Case 1:22-cV-10904-JSR Document 243-24 Filed 07/25/23 Page 8 of 8
+CERTIFICATE OF SERVICE
+I hereby certify that on April 11, 2023, the foregoing document, titled "JPMorgan Chase
+Bank, N.A.'s Supplemental Responses and Objections to Plaintiff's First Set of Interrogatories,"
+was served in accordance with the Federal Rules of Civil Procedure and the Local Rules of the
+United States District Court for the Southern District of New York upon the attorneys for the
+plaintiff' in the above-entitled action by electronic mail.
+DATED:
+April 11, 2023
+New York, NY
+Iden Butts
+By:
+John J. Butts
+- 7-

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+  "input_sha256": "72e2ad3c6a2cdba3d66de3f7d4d7eff3a01d69fd799b4bdc116275b88cbdab36",
+  "output_sha256": "29feef42b5f7d8f8a62a6f1835e17fc756cf3298b759ccf407a47bba67d5d81b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/c76a12469440fedc1ea23fc8d247570b460ade8a4a0845a2730f777f911abb03.md

@@ -0,0 +1,51 @@
+Case 1:22-cv-10904-JSR Document 102-1 Filed 03/28/23 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+GOVERNMENT OF THE UNITED STATES
+VIRGIN ISLANDS,
+Plaintiff,
+V.
+Case No. 22-cv-10904-JSR
+AFFIDAVIT OF
+BRENDAN V.
+,, Jr.
+IN SUPPORT OF MOTION FOR
+ADMISSION PRO HAC VICE
+JPMORGAN CHASE BANK, N.A.,
+Defendant /
+Third-Party Plaintiff
+JPMORGAN CHASE BANK, N.A.,
+Third-Party Plaintiff,
+V.
+JAMES EDWARD STALEY,
+Third-Party Defendant.
+DECLARATION OF BRENDAN V.
+, Jr.
+1, Brendan V.
+1. I am a partner at
+Jr., do declare as follows:
+& Connolly LLP, 680 Maine Avenue S.W., Washington, D.C.
+20024.
+2. I am a member in good standing of the bars of Rhode Island and the District of Columbia.
+3. I have never been convicted of a felony.
+4. I have never been censured, suspended, disbarred, or denied admission or readmission by
+any court.
+5. There are no pending disciplinary proceedings against me in any state or federal court.
+
+
+Case 1:22-cv-10904-JSR Document 102-1 Filed 03/28/23 Page 2 of 2
+I declare under penalty of perjury that the foregoing is true and correct.
+Dated: March 28, 2023
+Bandan sle
+Brendan V.:
+Subscribed and sworn to before me
+This 28 day of March 2023
+Ing fisch
+My Commission Expires
+INEZY.NOCHO
+NOTARY PUBLIC DISTRICT OF COLUMBIA
+My Commission Empires May 31, 2023
+JARY PUD
+EXP.
+5-31-23
+2

vision-fixhub/court-05/c76a12469440fedc1ea23fc8d247570b460ade8a4a0845a2730f777f911abb03.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "c76a12469440fedc1ea23fc8d247570b460ade8a4a0845a2730f777f911abb03",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "336e4d0686aa17d3e7b7131827a8607e2fd02b408413b9ea71a225d3e63b259b",
+  "output_sha256": "ed25c55e0a561f8525f8998c7207a5e6a4dbdb83a0f22ae2ab8a4bca339a2c6c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/c76a9e9cb8c8e4bad5b889ee45215ef011cdd04789a840f1ce22d98285096aba.md

@@ -0,0 +1,194 @@
+Case 1:22-cv-10904-JSR Document 145 Filed 05/15/23 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+GOVERNMENT OF THE UNITED STATES
+VIRGIN ISLANDS,
+Plaintiff,
+Case No. 22-cv-10904 (JSR)
+V.
+JPMORGAN CHASE BANK, N.A.,
+Defendant/Third-Party
+Plaintiff.
+JP
+CHASE BANK, N.A.,
+Third-Party Plaintiff,
+V.
+JAMES EDWARD STALEY,
+Third-Party Defendant.
+MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT JPMORGAN CHASE
+BANK, N.A.'S MOTION FOR ORDER AUTHORIZING ALTERNATIVE SERVICE OF
+SUBPOENA ON THIRD PARTY CELESTINO A.
+JPMorgan Chase Bank, N.A. ("JPMC") respectfully submits this memorandum of law in
+support of its motion for an order authorizing alternative service pursuant to Federal Rule of Civil
+Procedure Rule 45 in order to serve a subpoena for testimony and documents (the "Subpoena")
+via email on third party Celestino A.
+INTRODUCTION
+, Sr. ("'Mr.
+Despite diligent efforts over the past month to serve the Subpoena on Mr.
+, JPMC
+has been unable to do so. As detailed below, JPMC attempted to personally serve the Subpoena
+
+
+Case 1:22-cv-10904-JSR Document 145 Filed 05/15/23 Page 2 of 6
+on Mr.
+on four different occasions. No attempt has been successful to date, and there is no
+guarantee that personal service will succeed going forward with Mr.
+However, JPMC does have a means of communicating with Mr.
+Specifically,
+JPMC's local counsel in the United States Virgin Islands ("USVI"), Kevin A. Rames, has been
+able to obtain Mr.
+known email address and send correspondence to that address. JPMC
+thus proposes using this email address as an alternative means of service of the Subpoena. As Mr.
+undoubtedly will receive actual notice of the Subpoena if it is served via email to this
+address, JPMC respectfully asks this Court to enter an order authorizing JPMC to serve Mr.
+via email.
+II. RELEVANT FACTUAL BACKGROUND
+A.
+JPMC's Ability to Depose Mr.
+is Integral to this Case
+Mr.
+served eleven terms, or twenty-two years, as a Senator in the USVI Legislature.
+Mr.
+is currently a member of the Board of Governors of the Virgin Islands Port Authority
+(VIPA"). One of Plaintiffs' key contentions in this case is that Defendant JPMC helped Jeffrey
+Epstein fraudulently conceal allegedly illegal conduct from the USVI Government. Second
+Amended Complaint ("SAC""), ECF. No. 119, at 9| 123. Mr.
+having worked for the USVI
+Government, is uniquely situated in this fact discovery stage to help JPMC uncover the extent of
+the USVI Government's knowledge of the allegedly illegal conduct. As such, Defendants' ability
+to depose Mr.
+is integral to its ability to litigate this case.
+B.
+JPMC Attempts Unsuccessfully to Serve the Subpoena on Mr.
+On May 1, 2023, JPMC issued the Subpoena to Mr.
+requiring him to (i) produce
+certain documents and records and (ii) appear for an in-person deposition (attached as Exhibit I).
+See Declaration of Felicia Ellsworth (the "Ellsworth Declaration"), 1 2 (attached as Exhibit 2).
+JPMC, through its process server, diligently, but unsuccessfully, attempted to serve Mr.
+2
+
+
+Case 1:22-cv-10904-JSR Document 145 Filed 05/15/23 Page 3 of 6
+with the Subpoena on April 24, 2023. See Affidavit of Marlon
+(the "
+Affidavit") (attached as Exhibit 3). JPMC's local counsel in the USVI, Kevin A. Rames, spoke
+with Mr.
+via his cell phone on April 27, 2023. Ellsworth Declaration, 9 4. Mr. |
+informed Mr. Rames that he would cooperate with service by the process server at any time before
+May 7, 2023. Id. Thereafter on May 2, 6, and 7, 2023, JPMC, through its process server,
+diligently, but unsuccessfully, again attempted to serve Mr. I
+with the Subpoena. See
+Affidavit.
+Despite multiple efforts, JPMC was unable to personally serve Mr. L
+with the
+Subpoena. This is because Mr.
+actively evaded service of process on four different
+occasions and subsequently failed to respond to multiple follow-up telephone calls from Mr.
+Rames. Ellsworth Declaration, 11 6-7. On May 8, 2023, the process server called Mr.
+, who
+stated that he was at the airport and going to be out of territory until May 23, 2023. Id., 18. While
+JPMC's process server will be at the airport on May 23, 2023 to again attempt personal service on
+Mr.
+there is no guarantee that such efforts will succeed. However, Mr. Rames has been
+able to send correspondence to Mr.
+via his known email address within the last week. Id.,
+99.
+III. ARGUMENT
+A.
+Service via Email is a Reliable and Expeditious Means of Service that is
+Likely to Reach Mr.
+Pursuant to Federal Rule of Civil Procedure 45, this Court may authorize "alternative
+service that is reasonably designed to ensure that a witness actually receives a subpoena." See
+SEC v. Pence, 322 F.R.D. 450, 454 (S.D.N.Y. 2017) (citations omitted); see also Cordius Trust v.
+Kummerfeld, 2000 WL 10268, at *2 (S.D.N.Y. Jan. 3, 2000) (authorizing alternative service of
+subpoena that "reasonably insures actual receipt of the subpoena"). Alternative service is
+3
+
+
+Case 1:22-cv-10904-JSR Document 145 Filed 05/15/23 Page 4 of 6
+appropriate where it "reasonably insures actual receipt of the subpoena by the witness" and "is
+reasonably calculated under the circumstances to provide [the witness] with both notice and an
+opportunity to present objections." See JPMorgan Chase Bank, N.A. v. IDW Grp., LLC, 2009 WL
+1313259, at *3 (S.D.N.Y. May 11, 2009) (citations omitted); see also In re Bibox Grp. Holdings
+Ltd. Secs. Litig., 2020 WL 4586819, at *2 (S.D.N.Y. Aug. 10, 2020) ("[I]n order to comply with
+due process requirements, alternative service must provide notice that is reasonably calculated
+under all the circumstances, to apprise interested parties of the pendency of the action.") (citations
+and quotations marks omitted).
+This district has held that service via email complies with constitutional notions of due
+process, especially where the facts show that the party to be served likely will receive the process
+served at the given email address. See NYKCool A.B. v. Pacific Int'l Servs., Inc., 66 F.Supp.3d
+385, 391 (S.D.N.Y. 2014) ("As a general matter, in those cases where service by email has been
+judicially approved, the movant supplied the Court with some facts indicating that the person to
+be served would be likely to receive the summons and complaint at the given email address."); see
+also SEC v. David, 2020 WL 703464, at *1 (S.D.N.Y. Feb. 12, 2020) ("IT]he Court is persuaded
+that alternative service by email is warranted in this case."); Sulzer Mixpac AG v. Medenstar, 312
+F.R.D. 329, 331 (S.D.N.Y. 2015) ("[T]he Court grants plaintiff's motion to serve defendant at the
+email address listed on Medenstar's Internet homepage...."); see also Pearson Educ. Inc. v. Doe
+1, 2019 WL 6498305, at *3 (S.D.N.Y. Dec. 2, 2019) ("Email service has also repeatedly been
+found by courts to meet the requirements of due process."); F.T.C. v. PCCare247 Inc., 2013 WL
+841037, at *4 (S.D.N.Y. March 7, 2013) ("Service by email alone comports with due process
+where a plaintiff demonstrates that the email is likely to reach the defendant.").
+4
+
+
+Case 1:22-cv-10904-JSR Document 145 Filed 05/15/23 Page 5 of 6
+Moreover, because JPMC's process server was able to make contact with Mr.
+via
+his cell phone, Mr.
+already has knowledge of the lawsuit. This district has held that,
+"Service by alternative means is all the more reasonable where a defendant demonstrably already
+has knowledge of the lawsuit." Marvici v. Roche Facilities Maintenance LLC, 2021 WL 5323748,
+at *5 (S.D.N.Y. Oct. 6, 2021) (citing SEC v. Tome, 833 F.2d 1086, 1093 (2d Cir. 1987)).
+Finally, as the USVI Government argued in its own motion for alternative subpoena
+service, ECF No. 132, this Court has allowed alternative service where multiple attempts at
+personal service have failed, see SEC v. David, No. 19-cv-9013, 2020 WL 703464, at *1-2
+(S.D.N.Y. Feb. 12, 2020) (Rakoff, J.), or where the parties are "approaching close of discovery,"
+In re Petrobras Securities Litig., No. 14-CV-9662, 2016 WL 908644, at *1-2 (S.D.N.Y. March 4,
+2016) (Rakoff, J.) (authorizing alternative service by email and overnight mail 56 days before the
+discovery cutoff). As explained above, JPMC diligently attempted personal service of the
+Subpoena on Mr.
+multiple times but was unable to do so, as Mr.
+actively evaded
+service. In addition, fact discovery in our case closes in just fifteen days.
+As such, alternative service is more than warranted here. Service of the Subpoena on Mr.
+via email will comply with constitutional notions of due process and provide Mr.
+with sufficient notice of the Subpoena.
+IV.
+CONCLUSION
+For the foregoing reasons, JPMC respectfully asks the Court to enter an order authorizing
+service of the Subpoena on Mr.
+_by email. If the Court enters an order authorizing alternative
+service of the Subpoena on Mr.
+, JPMC will serve the Subpoena on Mr.
+at his known
+email address.
+5
+
+
+Case 1:22-cv-10904-JSR Document 145 Filed 05/15/23 Page 6 of 6
+Dated: May 15, 2023
+Respectfully submitted
+WILMER CUTLER PICKERING
+HALE AND DORR LLP
+/s/ Felicia H. Ellsworth
+Felicia H. Ellsworth
+John J. Butts
+60 State Street
+Boston,
+02109
+(t) (617) 526-6000
+(f) (617) 526-5000
+felicia.ellsworth@wilmerhale.com
+john.butts@wilmerhale.com
+_Ill
+Robert L. Boone
+Hillary Chutter-Ames
+7 World Trade Center
+250 Greenwich Street
+New York, NY 10007
+(t) (212) 230-8800
+(f (212) 230-8888
+robert.boone@wilmerhale.com
+hillary.chutter-ames@wilmerhale.com
+Attorneys for JPMorgan Chase Bank, N.A.
+6

vision-fixhub/court-05/c76a9e9cb8c8e4bad5b889ee45215ef011cdd04789a840f1ce22d98285096aba.receipt.json

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

vision-fixhub/court-05/c76fbdc26bdd94082d991351c488bd5de48c734a9e1eaeaf97e1c70fd890db76.md

@@ -0,0 +1,4 @@
+Case 1:22-cv-10904-JSR Document 297-12 Filed 08/18/23
+
+
+FILED UNDER SEAL

vision-fixhub/court-05/c76fbdc26bdd94082d991351c488bd5de48c734a9e1eaeaf97e1c70fd890db76.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -33,
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+  "doc_id": "c76fbdc26bdd94082d991351c488bd5de48c734a9e1eaeaf97e1c70fd890db76",
+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
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+}

vision-fixhub/court-05/c77760075c67469808ea4e0730cb1125e61d67a3d3719ec3c6f366e2399c5af1.md

@@ -0,0 +1,31 @@
+Case 1:22-cv-10904-JSR Document 244-2 Filed 07/25/23 Page 1 of 2
+
+
+
+7/20/23, 7:02 PM
+The New Hork Fimes
+Case 1:22-cv-10904-JSRP. MDacummentc4olo2Hedglech0 7125v23ronPtage 2 of 2
+J.P.
+to Buy Control of Hedge Fund
+By Reuters
+Sept. 28, 2004
+J.P.
+Chase plans to buy a majority stake in the hedge fund Highbridge Capital Management, the companies said
+yesterday, a sign that Wall Street is seeking a bigger role in the growing hedge fund industry.
+unit, J.P.
+investors.
+Fleming Asset and Wealth Management, said Highbridge would help attract a broader
+audience of investors to hedge funds, a vehicle once regarded as solely for institutional investors and very wealthy private
+B. Whelan, chief executive of VAN Hedge Fund Advisors International, said: "This is going to bring hedge funds
+more into the mainstream. As hedge funds become part of the mainstream asset-management business, more and more
+institutions are investing in these funds, and more asset managers are looking to acquire."
+If such deals gather steam, though, that could add to the risks for Wall Street, as it moves from servicing hedge funds to
+an active role in managing the volatile, if potentially lucrative, investments.
+The terms of the Highbridge transaction were not disclosed. Highbridge will operate as a separate entity managed by its
+founders, Glenn R.
+and Henry Swieca,
+and Highbridge said.
+Highbridge manages $7 billion in assets and has offices in London, Hong Kong and New York, where it is based.
+A version of this article appears in print on, Section C, Page 12 of the National edition with the headline: J.P.|
+to Buy Control of Hedge Fund
+111

vision-fixhub/court-05/c77760075c67469808ea4e0730cb1125e61d67a3d3719ec3c6f366e2399c5af1.receipt.json

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+{
+  "byte_delta": -35,
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
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+}

vision-fixhub/court-05/c77792f47111b46a6122feb8a9fdadebcf1cc60f30c75353baf2fae28f6becec.md

@@ -0,0 +1,84 @@
+Case 1:22-cv-10904-JSR Document 95
+Filed 03/24/23 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE 1, Individually and on
+Behalf of All Others Similarly
+Situated,
+22-cv-10018 (JSR)
+Plaintiff,
+-y-
+DEUTSCHE BANK AKTIENGESELLSCHAFT,
+DEUTSCHE BANK AG NEW YORK BRANCH,
+DEUTSCHE BANK TRUST COMPANY
+AMERICAS,
+Defendants.
+JANE DOE 1, Individually and on
+Behalf of All Others Similarly
+Situated,
+22-cv-10019 (JSR)
+Plaintiff,
+-V-
+JP
+CHASE BANK, N.A.,
+Defendant.
+GOVERNMENT OF THE UNITED STATES
+VIRGIN ISLANDS,
+Plaintiff,
+22-CV-10904 (JSR)
+ORDER
+-v-
+JP
+CHASE BANK, N.A.,
+Defendant.
+1
+
+
+Case 1:22-cv-10904-JSR Document 95 Filed 03/24/23 Page 2 of 3
+JED S. RAKOFF, U.S.D.J.:
+On March 1, 2023, defendant JPMorgan Chase Bank, N.A. ("JP
+) moved to compel production of certain documents from thirdparty the Epstein Victims Compensation Program ("EVCP"). For reasons
+stated from the bench on March 16, 2023, the Court hereby grants JP
+motion in part and denies that motion in part, as further
+specified below.
+The Court hereby grants JP
+motion with respect to its
+Requests for Production numbered 1, 9, 12, 13, 14, and 15.
+Additionally, the Court hereby grants in part JP
+motion with
+respect to its Requests for Production numbered 7 and 8. More
+specifically, the EVCP is hereby ordered to produce documents
+sufficient to show the total number of applicants to the EVCP who were
+approved for compensation and the total number of such applicants who
+were denied such compensation. The EVCP is not hereby compelled to
+produce documents sufficient to show the reasons for its approval or
+denial of any application. Additionally, JP
+motion to compel
+is denied with respect to Requests for Production numbered 13, 16, 17,
+and 19, which the Court views as overly broad.
+2
+
+
+Case 1:22-cv-10904-JSR Document 95 Filed 03/24/23 Page 3 of 3
+All documents produced pursuant to this Order are to be produced
+on an attorneys-eyes-only basis, and are to be made available to
+counsel for JP
+well as to counsel for defendants in Jane Doe
+V. Deutsche Bank Aktiengesellschaft et al.r 22-cv-10018. A11
+personally identifying information must be redacted from them, and
+they must be returned (with no records of them kept) once the Court
+has ruled on class certification in the above-captioned cases.
+The Clerk is respectfully directed to close entry number 55 on
+the docket of Jane Doe v. JP
+Chase Bank, N.A., 22-cv-10019 and
+entry number 63 on the docket of Government of the United States Virgin
+Islands v. JP
+Chase Bank, N.A., 22-cv-10904.
+SO ORDERED.
+New York, NY
+March 24, 2022
+JED
+ges. Robel
+RAKOFF,
+S.D.J.
+3

vision-fixhub/court-05/c77792f47111b46a6122feb8a9fdadebcf1cc60f30c75353baf2fae28f6becec.receipt.json

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vision-fixhub/court-05/c77e8d8134ffab6179c81be6e7a515b6552c36fe560f511cf319cd836caca347.md

@@ -0,0 +1,4 @@
+Case 1:22-cv-10904-JSR Document 326-29 Filed 09/08/23
+
+
+FILED UNDER SEAL

vision-fixhub/court-05/c77e8d8134ffab6179c81be6e7a515b6552c36fe560f511cf319cd836caca347.receipt.json

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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
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+}

vision-fixhub/court-05/c78c9ea41c517b57e82e79db653ba0215f8e6843122f2a7635bde6cf2421c02e.md

@@ -0,0 +1,30 @@
+Case 1:22-cv-10904-JSR Document 60 Filed 02/24/23 Page 1 of 1
+UNITED STATES DISTRICT COURT FOR THE
+SOUTHERN DISTRICT OF NEW YORK
+GOVERNMENT OF THE UNITED
+STATES VIRGIN ISLANDS
+PLAINTIFF,
+Case Number: 1:22-cv-10904 JSR
+MOTION FOR ADMISSION
+PRO HAC VICE
+V.
+JPMORGAN CHASE BANK, N.A.
+DEFENDANT.
+)
+Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and
+Eastern Districts of New York, I, Brendan Austin, hereby move this Court for an Order for
+admission to practice Pro Hac Vice to appear as counsel for Plaintiff, the Government of the United
+States Virgin Islands, in the above-captioned action.
+I am in good standing of the bars of the State of California 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: February
+, 2023
+Respectfully Submitted,
+BRENDAN AUSTIN
+Motley Rice LIC
+401 gth Street NW, Suite 630
+Washington, DC 20004
+(202) 386-9608 phone
+baustin@motleyrice.com

vision-fixhub/court-05/c78c9ea41c517b57e82e79db653ba0215f8e6843122f2a7635bde6cf2421c02e.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "c78c9ea41c517b57e82e79db653ba0215f8e6843122f2a7635bde6cf2421c02e",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8dae0045286db9fdbceb6570ad8c3a27238b10dc09a3d8a0699a8d2fd1dbf8dd",
+  "output_sha256": "28dbfd37b6cc6bc1ae05203be7d7d3801964f9ea5e83d803914364d794c2f136",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/c793b386a0655a5a2cd327e0b5bad2723cdaf3fdcad8eac1710f02cadfeb0344.md

@@ -0,0 +1,3 @@
+Case 1:22-cv-10904-JSR Document 158-101 Filed 05/23/23 Page 1 of 1
+
+FILED UNDER SEAL

vision-fixhub/court-05/c793b386a0655a5a2cd327e0b5bad2723cdaf3fdcad8eac1710f02cadfeb0344.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -23,
+  "dataset": "marble-joined",
+  "doc_id": "c793b386a0655a5a2cd327e0b5bad2723cdaf3fdcad8eac1710f02cadfeb0344",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "50d1db1a70e171fa59c0c7dfe5e65076249fa91b53e390d2b8844217f276ed77",
+  "output_sha256": "551cabedadae978fca2cf04cee95d12f94e00f7d4a2ddc7cbde0ef82a6847e7e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/c7d6c6199a0fdc0c7631057ae525e034ddfd06c58a8f31211ccec4a9ca11e17e.md

@@ -0,0 +1,54 @@
+Case 1:20-cr-00330-PAE Document 686
+Filed 06/27/22
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+
+USDC SDNY
+DOCU
+ELECTRONICALLY FILED
+Doc I
+DATE FILED: 06/27/2022
+United States of America,
+-V-
+Ghislaine Maxwell,
+20-CR-330 (AJN)
+ORDER
+Defendant.
+ALISON J. NATHAN, Circuit Judge, sitting by designation:
+The Court has now received and docketed the full set of submissions related to victim
+impact statements that were filed in accordance with this Court's prior order. Dkt. No. 668. The
+Court received statements from
+Kate,
+, and
+As indicated in its prior order, the Court will exercise its discretion to permit all of these
+individuals to be heard in writing. Dkt. No. 682. The Court also denied the Defendant's
+redaction requests. Id. All unredacted statements are now part of the record. Dkt. Nos. 674,
+675-1.
+Also as previously indicated in its order, the Court will permit
+Kate, and
+to make an oral statement at sentencing if they wish to do so. Dkt. No. 682.
+Further, having now reviewed the full set of requests, and having heard from the
+Government that it does not object, Dkt. No. 678, the Court deems it feasible to exercise its
+discretion to permit the remaining individuals who seek to themselves make an oral statement at
+sentencing to do so. They are:
+and
+In order to
+feasibly accomplish this in light of the anticipated length of the sentencing proceeding, while
+ensuring fairness and avoiding delay of sentencing, each individual speaking orally may read a
+1
+
+
+Case 1:20-cr-00330-PAE Document 686 Filed 06/27/22 Page 2 of 2
+shortened version of their previously submitted written statement. The Court deems counsel for
+the individuals to be responsible for ensuring that anticipated statements conform to this
+requirement.
+The Government shall promptly provide copies of this order to counsel for the eight
+individuals who submitted statements.
+SO ORDERED
+Dated: June 27, 2022
+New York, New York
+Ali i Notor
+ALISON J. NATHAN
+United States Circuit Judge,
+sitting by designation
+2

vision-fixhub/court-05/c7d6c6199a0fdc0c7631057ae525e034ddfd06c58a8f31211ccec4a9ca11e17e.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -35,
+  "dataset": "marble-joined",
+  "doc_id": "c7d6c6199a0fdc0c7631057ae525e034ddfd06c58a8f31211ccec4a9ca11e17e",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "e5d3e0b649847c39efce813bd0bacf3f2bbb3b5a2071008d9d8101ff3ec2cfa0",
+  "output_sha256": "e8c708e4418e9fc2438ff7fc5e3d2d0f6ce9afdb2e167a04239c4ceac234cce8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/c7f6781248e3dae0c6b0557b8a88f7a5f26afb6f72069d69d70be40f4a0450b1.md

@@ -0,0 +1,3 @@
+Case 1:22-cv-10904-JSR Document 158-110 Filed 05/23/23 Page 1 of 1
+
+FILED UNDER SEAL

vision-fixhub/court-05/c7f6781248e3dae0c6b0557b8a88f7a5f26afb6f72069d69d70be40f4a0450b1.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -23,
+  "dataset": "marble-joined",
+  "doc_id": "c7f6781248e3dae0c6b0557b8a88f7a5f26afb6f72069d69d70be40f4a0450b1",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "4746a2002158f8b325313a4ee6aa1cc95a3b06dca06c63c570fbfb65d93f24a8",
+  "output_sha256": "9efeb84ee68646c8d85113e1cb4312db23f205177afafbe39aaba43996eb4587",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-05/c804c2ad1f7ea7df6a12740afa2008e6b595b1c1d35b9bddad69c28a5d41b1ab.md

@@ -0,0 +1,685 @@
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 1 of 18
+
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 2 of 18
+JULY 2004
+Working group list
+Last updated July 12, 2004
+STRICTLY PRIVATE
+AND
+ONFIDENTIAL
+For edits to the WGL please contact Victor Dupont at 212-622-6089 or victor.r.dupont@jpmorgan.com
+Do not delete this paragraph mark
+Do not delete this paragraph mark
+
+JPM-SDNYLIT-00724984
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 3 of 18
+
+JPMorgan Asset and Wealth Management
+522 Fifth Avenue, 3° Floor
+Name
+Jes Staley
+AWM CEO
+Asst: Mullin, Christine M.
+Tel: (212) 837-2378
+Email: mullin_chrissy@jpmorgan.com
+David Brigstocke
+Office phone and email
+Tel: (212) 837-2375
+Fax: (212) 837-5003
+Email: jes.staley@jpmorgan.com
+Tel: (212) 837-9333
+Fax: (212) 837-2601
+Asst: Adele Engerer
+Email:
+Tel: (212) 837-2251
+Email: adele.engerer@jpmorganfleming.com
+david.hc.brigstocke@jpmorgan.com
+Roy Kinnear
+Tel: (212) 837-2772
+Global Investment Management CFO
+Asst: Adele Engerer
+Fax: (212) 837-2601
+Email:
+Tel: (212) 837-2251
+roy.kinnear@jpmorganfleming.com
+Email: adele.engerer@jpmorganfleming.com
+20 Finsbury Street, Floor 4
+London, EC2Y9AQ
+United Kingdom
+Name
+Pablo Forero
+Investment Mgmt.., MD
+Asst: Suzie Powell
+Tel: (44-20) 7-742-8547
+Email:
+suzie.j.powell@jpmorganfleming.com
+Office phone and email
+Tel: (44-20) 7-742-3897
+Fax: (44-20) 7-742-5090
+Email: pablo. forero@jpmorganfleming.com
+20 Finsbury Street, Floor 6
+London, EC2Y9AQ
+United Kingdom
+Paul Bateman
+Investment Mgmt. CEO
+Asst: Jacquie Crinnon
+Tel: (44-20) 7-742-4037
+jacquie.crinnion@jpmorganfleming.com
+Office phone and email
+Tel: (44-20) 7-742-8475
+Fax: (44-20) 7-742-8024
+Email: paul.bateman@jpmorganfleming.com
+
+JPM-SDNYLIT-00724985
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 4 of 18
+522 Fifth Avenue, 15th Floor
+Name
+Larry Unrein
+Private Equity, MD
+Asst: Debra Ogden
+Tel: (212) 837-1740
+Email: debra.l.ogden@jpmorgan.com
+Julian Shles
+Private Equity, MD
+Asst: Laura Riccardelli
+Tel: (212) 837-1726
+Email:
+laura.riccardelli@jpmorganfleming.com
+
+Office phone and email
+Tel: (212) 837-2225
+Email:
+@jpmorganfleming.com
+Tel: (212) 837-2643
+Fax: (212) 837-1377
+Email: julian.shles@jpmorganfleming.com
+522 Fifth Avenue, 18" Floor
+AWM Corporate Development, VP
+Asst: Stephanie Roman
+Tel: (212) 837-1533
+Email:
+Stephanie.n.roman@jpmorgan.com
+Anne Grissinger
+AWM VP
+Office phone and email
+Tel: (212) 837-1080
+Fax: (212) 837-5041
+Email: |
+@jpmorgan.com
+Tel: (212) 837-1088
+Email: anne.p.grissinger@jpmorgan.com
+8 Connaught Road Central, Floor 21
+Hong Kong
+Name
+Roger Hepper
+COO, JF Asset Mangement Limited
+Asst: Anita Wai Yi Tang
+Tel: (852) 2800-2807
+Email: anita.tang@jfam.com
+Office phone and email
+Tel: (852) 2800-2801
+Email: roger.hepper@jfam.com
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 5 of 18
+
+JP
+Chase Executive Management
+270 Park Avenue, Floor 8
+Name
+Bill
+Chairman and CEO
+Asst: Ellen Guobis-
+Tel: (212) 270-3434
+Email:
+David Coulter
+ice Chairman, Investment Bar
+sst: Katharine W
+Tel: (212) 270-0121
+Email: kathleen.will@chase.com
+Office phone and email
+Tel: (212) 270-4019
+Email:
+Tel: (212) 270-2494
+Fax: (212) 270-0880
+Email: david.a.coulter@chase.com
+1 Bank One Plaza, Floor 9
+Chicago, IL 60670
+Name
+Jamie Dimon
+Chairman, CEO and President
+Asst: Nancy Falco
+Tel: (212) 270-1121
+Email: falco_nancy@jpmorgan.com
+Office phone and email
+Tel: (312) 336-2222
+Fax: (312)-732-6400
+Email: jamie_dimon@bankone.com
+270 Park Avenue, Floor 9
+Name
+Dina Dubion
+EVP and CFO
+Asst: Anna Maria Consani
+Tel: (212) 270-6916
+mail: cathy.boyle@chase.com
+Office phone and email
+Tel: (212) 270-9735
+Fax: (212) 270-1604
+Email: dina.dublon@chase.com
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 6 of 18
+
+JPMorgan Chase Corporate Development
+270 Park Avenue, 9th Floor
+Name
+Jay Mandelbaum
+Executive Vice President
+Asst: Aileen Rodriguez
+Tel: (212) 277-1573
+Email:
+aileen_f_rodriguez@bankone.com
+Office phone and email
+Tel: (212) 277-1568
+Fax: (212) 277-1506
+Email: jay_mandelbaum@bankone.com
+1 Bank One Plaza, 9th Floor
+Chicago, IL 60670
+Name
+Brian Bessey
+Senior Vice President
+Asst: Stephanie
+Tel: (212) 270-0999
+Email:
+Office phone and email
+Tel: (212) 270-4657
+Fax: (212) 270-5553
+Email: brian_a_bessey@bankone.com
+270 Park Avenue, 37th Floor
+Name
+Jim Schimmel
+JPM Corporate Development, VP
+Ast: 212) 270 right
+Email: francine.knight@chase.com
+Alice Lin
+Legal, Associate
+Asst: Francine Knight
+Tel: (212) 270-2259
+Email: francine.knight@chase.com
+Office phone and email
+Tel: (212) 270-9743
+Fax: (212) 270-0659
+Email: james.schimmel@chase.com
+Tel: (212) 270-9037
+Fax: (212) 270-0659
+Email: alice.lin@jpmorgan.com
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 7 of 18
+
+JPMorgan Chase Corporate Treasury
+270 Park Avenue, 28th Floor
+Name
+David Edelson
+Treasurer
+Asst: Catherine Boyle
+Tel: (212) 270-9312
+Email: cathy.boyle@chase.com
+Rich Landau
+Capital & Liquidity Mgmt., MD
+Asst: Starlett
+Tel: (212) 270-6290
+Email:
+Lou Morrell
+Finance & Risk Memt., MD
+Asst: Starlett |
+Tel: (212) 270-6290
+Email: |
+Office phone and email
+Tel: (212) 270-7002
+Fax: (212) 270-9589
+Email: david.edelson@jpmchase.com
+Tel: (212) 270-6291
+Fax: (212) 270-0819
+Email: richard.landau@chase.com
+Tel: (212) 270-9737
+Fax: (212) 270-0819
+Email: lou.morrell@chase.com
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 8 of 18
+
+JPMorgan Controllers & Accounting Policy
+245 Park Avenue, Floor 10
+Name
+David Morris
+Controllers, Senior Vice
+President
+Asst:
+Corbin
+Tel: (212) 270-6290
+Email:
+Office phone and email
+Tel: (212) 648-0377
+Fax: (646) 534-6126
+Email: david.m.morris@jpmchase.com
+Arthur Kirshenbaum
+Corporate accounting, Vice
+President
+Audrey Senior
+Vice President
+Tel: (212) 648-0384
+Fax: (646) 534-6132
+Email: arthur.kirshenbaum@chase.com
+Tel: (212) 648-0389
+Fax: (646) 534-6132
+Email: audrey.n.senior@chase.com
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 9 of 18
+
+JPMorgan Tax Group
+245 Park Avenue, 8th Floor
+New York, NY 10167
+Name
+[Lopata
+Tax Group, MD
+Mark
+Tel: (212) 648-1111
+E-mail:
+Office phone and email
+Tel: (212) 648-1040
+Fax: (646) 534 6003
+Email:
+Tax Group, MD
+Asst:
+Mark
+Tel: (212) 648-1111
+E-mail: mark_lynn@jpmorgan.coml
+John Grimes
+Tax Group, VP
+Asst: Susan
+Tel: (212) 648-1052
+E-mail:
+Tel: (212) 648-1041
+Fax: (646) 534-6002
+Email:
+Tel: (212) 648-1043
+Fax: (646) 534-6003
+Email: john.m.grimes@jpmchase.com
+
+60ł982vH
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 10 of 18
+
+JPMorgan Legal
+270 Park Avenue, Floor 39
+Name
+Kathleen Juhase
+Senior Vice President
+Asst: Joanne Keamey
+Tel: (212) 270-2503
+Fax: (212) 270-5092
+Neila Radin
+Legal, Senior Vice President
+Asst: Eileen Cannon
+Tel: (212) 270-8219
+Email:
+Eileen.cannon@chase.com
+Office phone and email
+Tel: (212) 270-5907
+Fax: (646) 534-6126
+Email: juhase_kathleen@jpmorgan.com
+Tel: (212) 270-0938
+Fax: (212) 270-1222
+Email: neila.radin@chase.com
+
+PROJECT
+ALPHA
+522 Fifth Avenue, Floor 20
+Name
+James
+Vice President
+Asst: Daisha |
+Tel: (212) 837-1795
+Email: |
+270 Park Avenue, Floor 40
+Name
+Alice Chen
+Vice President
+Asst: Zenobia Souter
+Tel: (212) 270-3662
+Email: zenobia.j.souter@chase.com
+345 Park Avenue, Floor 5
+New York, NY 10154
+Name
+Anne Verdon
+Senior Vice President
+Asst: Linda Amenire
+Tel: (212) 464-2757
+Email: awenire_linda@jpmorgan.com
+522 5th Avenue, Floor 10
+Name
+Len Wallace
+Vice President
+Office phone and email
+Tel: (212) 837-1939
+Fax: (212) 837-2631
+Email: James.casey2@jpmorgan.com
+Office phone and email
+Tel: (212) 270-2447
+Fax: (212) 270-7429
+Email: alice.chen@chase.com
+Office phone and email
+Tel: (212) 464-1656
+Fax: (212) 464-0302
+Email: anne.verdon@chase.com
+Office phone and email
+Tel: (212) 837-8964
+Fax: (917) 464-7309
+Email: leonard.f.wallace@jpmorgan.com
+JPM-SDNYLIT-00724992
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 11 of 18
+
+522 5th Avenue, Floor 16
+Name
+Tom
+Managing Director
+Asst: Jacqueline Gutierrez
+Tel: (212) 837-8926
+Email:
+Jacqueline.gutierrez@jpmorgan.com
+Office phone and email
+Tel: (212) 837-2580
+Fax: (212) 837-1108
+Email: 1
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 12 of 18
+
+JPMorgan Securities Inc.
+277 Park Avenue, 13th Floor
+New York, NY 10172
+Financial Institutions Coverage
+Name
+James von Moltke
+Managing Director
+Asst: Carol
+Tel: (212) 622-6057
+Jim Greenberg
+Managing Director
+Asst: Jill Haddad
+Tel: (212) 622-4699
+David Stawik
+Vice President
+Asst: Michele Armstrong
+Tel: (212) 622-6998
+K. Jamie Patterson
+Associate
+Asst: Deborah L
+Tel: (212) 622-6997
+James Glinski
+Associate
+Asst: Sheila Halpin
+Tel: (212) 622-6064
+Victor Dupont
+Analyst
+Asst: Angelique D
+Tel: (212) 622-2085
+Office phone and email
+Tel: (212) 622-6340
+Fax: (646) 534-1887
+Email: james. vonmoltke@jpmorgan.com
+Tel: (212) 622-6061
+Fax: (646) 534-1876
+Email: james.a.greenberg@jpmorgan.com
+Tel: (212) 622-6974
+Fax: (646) 534-3004
+Email: david.stawik@jpmorgan.com
+Tel: (212) 622-6320
+Fax: (646) 534-3004
+Email:
+Kristine.jamie.patterson@jpmorgan.com
+Tel: (212) 622-6976
+Fax: (646) 534-1892
+Email: james.d.glinski@jpmorgan.com
+Tel: (212) 622-6089
+Email: victor.r.dupont@jpmorgan.com
+1211 Avenue of the Americas
+New York, NY
+Name
+Dick Herbst
+Managing Director
+Asst: Rachel Harris
+Tel: (212) 622-606
+mail: rachel.r.harris@jpmchase.cor
+Office phone and email
+Tel: (212) 789-6089
+Fax: (212) 789-607
+Email: richard.herbst@jpmorgan.cor
+277 Park Avenue, 3ª Floor
+New York, NY 10172
+Name
+Richard Casavechia
+Managing Director
+Asst: Jayrie Moran
+Tel: (212) 622-2283
+Email: jaymie.moran@jpmorgan.com
+Office phone and email
+Tel: (212) 622-2499
+Fax: (212) 534-0135
+Email: richard.casavechia@jpmorgan.com
+
+JPM-SDNYLIT-00724994
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 13 of 18
+Cahill
+80 Pine Street
+New York, NY 10005
+General number: (212) 701-3000
+Fax: (212) 269-5420
+
+Name
+Gerald Tennenbaum
+Corporate partner
+Asst: Geri
+Tel: (212) 701-3226
+Email: gperez@cahill.com
+Office phone and email
+Tel: (212) 701-3224
+Fax: (212) 269-5420
+Email: gtennenbaum@cahill.com
+Jon Mark
+Corporate partner
+Asst: Mary Kupidlowski
+Tel: (212) 701-3795
+Email:
+mkupidlowski@cahill.com
+Ben
+Tax partner
+Asst: Gina Lawson
+Tel: (212) 701-3855
+Email: glawson@cahill.com
+Phil Heimowitz
+Council
+Asst: Rebekah Wilce
+Tel: (212) 701-3842
+Email: rwilce@cahill.com
+Tel: (212) 701-3100
+Fax: (212) 269-5420
+Email: jmark@cahill.com
+Tel: (212) 701-3853
+Tel: (212) 701-3624
+Fax: (212) 269-5420
+Email: pheimowitz@cahill.com
+Erica Swanson
+Tax associate
+Asst: Nicole DeLutr
+Tel: (212) 701-3643
+Email: ndelutri@cahill.com
+Tel: (212) 701-3624
+Fax: (212) 269-5420
+Email: eswanson@cahill.com
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 14 of 18
+
+Highbridge Capital Management
+9 West 57t Street, 27th Floor
+New York, NY 10019
+Tel: (212) 287-4900
+Fax: (212) 287-4915
+Name
+Glenn
+Henry Swieca
+Robert J. Caruso
+Managing Director, COO
+Ronald S. Resnick
+Managing Director, Chief
+Administrative Officer
+Office phone and email
+Tel: 212-287-4977
+Email:
+Tel: (212) 287-4714
+Fax: (212) 287-4915
+Email: bob@hcmny.com
+Tel: (212) 287-4900
+Fax: (212) 287-4915
+Email: ron@hcmny.com
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 15 of 18
+
+Sachs
+85 Broad Street, 18t Floor
+New York, NY 10004
+Tel: (212) 902-1000q
+Name
+Don Truesdale
+Managing Director
+Asst: Gloria Mallios
+Office phone and email
+Tel: (212) 902-6226
+Fax: (212) 357-0926
+Email: don.truesdale@gs.com
+Ivan
+Managing Director
+Asst: Sandra McMillan
+Tel: (212) 902-6877
+Fax: (212) 357-9110
+Email:
+Huntley Garriot
+Vice President
+Asst: Jennifer Marino
+Tel: (212) 902-6314
+Fax: (212) 357-0926
+Email: huntley.garriott@gs.com
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 16 of 18
+
+Financial Trust Company and Advisors
+6100 Red Hook Quarter, Suite B-3
+St.
+USVI 00802
+457 Madison Avenue, 4* Floor
+New York, NY 10022
+Name
+Jeffrey E. Epstein
+Asst: Adrienne Bausch
+Jeffrey Schartz
+Office phone and email
+Tel: (340) 775-2525
+Fax: (340) 775-2528
+NY:
+Tel: (212) 770-9895
+Fax: (212) 371-8042
+Tel: (576) 791-0044
+New York Strategy Group, LLC
+457 Madison Avenue, 4t Floor
+New York, NY 10022
+Name
+Darren K. Indyke, Esq.
+Office phone and email
+Tel: (212) 750-1176
+Fax: (212) 750-0381
+Email: dkiesq@aol.com
+Watchel & Masyr
+110 East 59th Street
+New York, NY 10022
+Name
+Steven J.
+Esq.
+Office phone and email
+Tel: (212) 909-9505
+Fax: (212) 909-9463
+Email:
+@wmllp.com
+Weil Gotshal & Manges
+767 Fifth Avenue, 28th Floor
+New York, NY
+Name
+Kenneth Heitner, Esq.
+Office phone and email
+Tel: (212) 310 8288
+Email: Kenneth.heitner@weil.com
+
+JPM-SDNYLIT-00724998
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 17 of 18
+
+KPMG
+345 Park Avenue, 2nd Floor
+New York NY 10154
+Tel: (212) 758-9700
+Fax: (212) 758-9819
+Name
+Mary Barnes
+Partner, Advisory services
+Asst: Minnie
+Miguel Sagarna
+Transaction services
+Jonathan Doherty
+Transaction services
+Office phone and email
+Tel: (212) 954-7475
+Tel: (212) 872-5543
+Fax: (212) 954-2609
+Email: msagama@kpmg.com
+Tel: (212) 872-6644
+Fax: (212) 954-7278
+Email: jddoherty@kpmg.com
+
+
+Case 1:22-cv-10904-JSR Document 285-86 Filed 08/15/23 Page 18 of 18
+
+Schulte Roth & Zabel LLP
+919 Third Ave.
+New York, NY 10022
+Tel: (212) 756-2000
+Fax: (212) 593-5955
+Name
+Andre Weiss
+Corporate Partner
+Asst: Donna
+Phillipe Benedict
+Tax partner
+Asst: Doris
+Kimberly Monroe
+Corporate associate
+Asst: Tina Bologna
+Office phone and email
+Tel: (212) 756-2431
+Email: andre.weiss@srz.com
+Tel: (212) 756-2124
+Email: philippe.benedict@srz.com
+Tel: (212) 756-2556
+Email: kimberly.monroe@srz.com

vision-fixhub/court-05/c804c2ad1f7ea7df6a12740afa2008e6b595b1c1d35b9bddad69c28a5d41b1ab.receipt.json

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vision-fixhub/court-05/c8210b4b9869cf69433b8f90e51b3255593aa7abcec00033d0c39e5bcba4dbb1.md

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+Case 1:22-cv-10904-JSR Document 60-4 Filed 02/24/23 Page 1 of 1
+UNITED STATES DISTRICT COURT FOR THE
+SOUTHERN DISTRICT OF NEW YORK
+GOVERNMENT OF THE UNITED
+STATES VIRGIN ISLANDS
+PLAINTIFF,
+Case Number: 1:22-cv-10904 JSR
+ORDER FOR ADMISSION
+PRO HAC VICE
+JPMORGAN CHASE BANK, N.A.
+DEFENDANT.
+The motion of Brendan Austin 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 off
+California and the District of Columbia; and that his contact information is as follows:
+Name:
+Brendan Austin
+401 g'h Street NW, Suite 630
+City/State/Zip: Washington, DC 20004
+(202) 386-9608
+baustin@motleyrice.com
+Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for
+Plaintiff, Government of the United States Virgin Islands, in the above-entitled 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.
+New York, NY
+February -
+_, 2023
+JED S. RAKOFF, U.S.D.J.

vision-fixhub/court-05/c8210b4b9869cf69433b8f90e51b3255593aa7abcec00033d0c39e5bcba4dbb1.receipt.json

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vision-fixhub/court-05/c82cbd16e126e0de0a0f9e42e01ecbfca22a0b0349398a627a57ee3b6c77fc4f.md

@@ -0,0 +1,684 @@
+Document 367
+Filed 07/30/24 Page 1 of 23
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE 1, Individually and on
+Behalf of .
+All Others
+Similarly
+Situated,
+22-cv-10019 (JSR)
+OPINION AND ORDER
+Plaintiff,
+-V-.
+JP
+CHASE BANK, N.A.,
+Defendant.
+GOVERNMENT OF THE UNITED STATES
+VIRGIN ISLANDS,
+Plaintiff,
+22-cv-10904 (JSR)
+-v-
+JP
+CHASE BANK, N.A.,
+Defendant.
+JED S. RAKOFF, U.S.D.J.:
+Before the Court is the motion of non-party the New York Times
+("the Times") to unseal five exhibits that were filed in the abovecaptioned actions. The exhibits contain excerpts of the deposition
+of plaintiff Jane Doe 1 ("Doe"). Three of the exhibits were filed
+in connection with summary judgment briefing in the underlying
+1
+
+
+Document 367 Filed 07/30/24 Page 2 of 23
+actions and all contain the same portion of Doe's deposition
+related to her alleged non-consensual interactions with Jes
+Staley. The other two exhibits were filed in connection with
+plaintiffs' motion for class certification and contain a different
+portion of Doe's deposition, where she recounts how she was
+initially recruited by Jeffrey Epstein. During the course of
+litigation, the Court granted the class certification motion, but
+never ruled on the summary judgment motions because the case
+settled while the motions were pending.
+The Times argues that the common law and First Amendment right
+of access to court filings mandate unsealing. Doe opposes unsealing
+all five exhibits, arguing that doing so would risk revealing her
+identity and would force her to relive her traumatic experiences.
+Plaintiff Government of the United States Virgin Islands opposes
+unsealing on similar grounds. Staley opposes unsealing only the
+summary judgment transcripts, arguing that they are not judicial
+documents, because the court never ruled on that motion, and that
+he has his own privacy interest in keeping Doe's untested
+allegations sealed.
+For the reasons set forth below, the Court grants in part and
+denies in part the Times' motion.
+2
+
+
+Document 367 Filed 07/30/24 Page 3 of 23
+I. Legal Standard
+"Federal courts employ two related but distinct presumptions
+in favor of public access to court proceedings and records: a
+strong form rooted in the First Amendment, and a slightly weaker
+form based in federal common law." United States ex rel. United
+States v. Am. Univ. of Beirut, 718 F. App'x 80, 81 (2d Cir. 2018).
+Both presumptions follow a three-step analysis, with their first
+step in common, viz., the court must first determine "whether the
+[filings arel judicial document[sl, as only judicial documents are
+subject to a presumptive right of public access, whether on common
+law or First Amendment grounds." United States v. HSBC Bank USA,
+N.A., 863 F.3d 125, 134 (2d Cir. 2017).
+At the second step of the First Amendment analysis, documents
+must satisfy one of two tests. Under one test, the right of access
+applies to documents that "have historically been open to the press
+and general public and
+•. public access [to those documents]
+plays a significant positive role in the functioning of the
+particular process in question." Lugosch v. Pyramid Co., 435 F.3d
+110, 120 (2d Cir. 2006) (citation and internal quotation marks
+omitted). Alternatively, "It]he second approach considers the
+extent to which the judicial documents are derived from or are a
+necessary corollary of the capacity to attend the relevant
+proceedings." Id. (citation and internal quotation marks omitted) .
+If either test is
+satisfied, the First Amendment right attaches
+3
+
+
+Case 1:22-cv-10904-JSR Document 367 Filed 07/30/24 Page 4 of 23
+and "sealing of the documents may be justified only with specific,
+on-the-record findings that sealing is necessary to preserve
+higher values and only if the sealing order is narrowly tailored
+to achieve that aim." Id. at 124.
+At the
+second step of the common law right of access, the
+court must determine the weight of the presumption by assessing
+the role of the "material at issue [plays] in the exercise of the
+Article III judicial power and the resultant value of such
+information to those monitoring the federal courts." United States
+v. Amodeo, 71 F.3d 1044, 1049 (2d. Cir. 1995) ("Amodeo II"). Then,
+"after determining the weight of the presumption of access, the
+court must balance competing considerations against [disclosure]."
+Lugosch, 435 F.3d at 120 (internal quotation marks omitted).
+As compared to the common-law right of access, the First
+Amendment right of access "is stronger and can only be overcome
+under
+more
+stringent circumstances than the common law
+presumption." United States v. Erie Cnty., 763 F.3d 235, 241 (2d
+Cir. 2014); see also Lugosch, 435 F.3d at 124 (classifying the
+First Amendment right as "more stringent"). Accordingly, when at
+the second step a court finds the First Amendment right attaches,
+it "need not . . . engage in such a common law analysis" because
+in any case where the First Amendment presumption of access is
+overcome,
+so too will the common-law presumption. Erie Cnty., 763
+F.3d at 241; see also Accent Delight Int'1 Itd. v. Sotheby's, 394
+4
+
+
+Case 1:22-cv-10904-JSR Document 367 Filed 07/30/24 Page 5 of 23
+E. Supp. 3d 399, 416 (S.D.N.Y. 2019) (same); In re Terrorist
+Attacks on September 11, 2001, 2020 WL 8611148, at *1 (S.D.N.Y.
+Oct. 2, 2020) (same); Newsday LIC v. Cnty. of Nassau, 730 F.3d
+156, 164 n.9 (2d Cir. 2013) ("Because in all cases where the First
+Amendment applies the common law right applies a fortiori, we need
+not address the common law right.").
+II. Discussion
+The exhibits the Times seeks to unseal are divided into two
+categories: (a) the summary judgment papers for the motion mooted
+by settlement and (b) the filings attached to the motion for class
+certification granted by the Court. Each category is discussed in
+turn.
+A. Exhibits Attached to the Motion for Summary Judgment
+1. Step One: Judicial Document Status
+As noted, the threshold requirement for the First Amendment
+or common law right of access to apply is that the item under
+scrutiny must constitute a judicial document. Staley argues that
+the summary judgment transcripts do not satisfy this requirement,
+because the case settled while the summary judgment motions were
+pending and before the Court ever ruled on the matters. See Staley
+Opp. (Dkt. 293) at 1-3.
+To be a judicial document, an item "must be relevant to the
+performance of the judicial function and useful in the judicial
+5
+
+
+Case 1:22-cv-10904-JSR Document 367 Filed 07/30/24 Page 6 of 23
+process." United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995)
+("Amodeo I"). In general, documents filed with the court that "ask
+the court to grant (or reject) some relief," such as "pleadings
+and summary judgment papers," satisfy this test. HSBC Bank, 863
+F.3d at 141-42. But "the mere filing of a paper or document with
+the court is insufficient to render that paper a judicial document
+subject to the right of public access." Trump v. Deutsche Bank AG,
+940 F.3d 146, 150 (2d Cir. 2019) (citation and internal quotation
+marks omitted).
+The Second Circuit has held that summary judgment papers
+qualify as judicial documents, at least as a general matter. See
+Lugosch, 435 F.3d at 121
+(holding that "documents submitted to a
+court for its consideration in a summary judgment motion are-as a
+matter of law-judicial documents" even though the summary judgment
+motion was still pending and had not yet been ruled on);
+Maxwell, 929 F.3d 41, 45 (2d. 2019) (finding denial of motion for
+summary judgment does not abrogate judicial documents status even
+when documents were not relied upon in ruling). Furthermore, the
+Second Circuit has held, at least with respect to pleadings that
+were filed under seal, "the fact that a suit is ultimately settled
+without a judgment on the merits does not impair .
+• judicial
+record status." Bernstein v. Bernstein Litowitz Berger & Grossmann
+ILP, 814 F.3d 132, 140 (2d Cir. 2016) (internal quotation marks
+omitted). However, the Second Circuit has not addressed the
+6
+
+
+Case 1:22-cv-10904-JSR Document 367 Filed 07/30/24 Page 7 of 23
+question of whether the settlement of a case while a summary
+judgment motion is pending impacts the judicial document status of
+those
+moving papers.
+Other courts
+to address the question have split on the issue.
+The Fourth Circuit has recently held that papers filed with a
+summary judgment motion continue to be judicial documents even
+where the case settles before the motion is ruled on. See United
+States ex rel. Oberg v. Nelnet, Inc., 105 F.4th 161, 173 (4th Cir.
+2024). District courts in the Second Circuit that have considered
+the issue have come out different ways. Compare l
+V. Maxwell,
+2020 WL 133570, at *2, 4 (S.D.N.Y. Jan. 13, 2020) ("[U]ndecided
+motions and the papers associated with them are not judicial
+documents, " since they are
+not part of any "live controversy to
+which the [Article III] judicial power can extend"), In re IBM
+Arbitration Agreement Litig., 2022 WL 3043220, at *2 (S.D.N.Y. Aug.
+2, 2022) (summary judgment filings mooted by granting prior motion
+to dismiss are not judicial documents since they have "no tendency"
+or "ability I| to influence this Court's ruling on [thel motion
+[to dismiss]") (alterations added); with Lohnn v. IBM, 2022 WL
+3359737, at *4 (S.D.N.Y. Aug. 15, 2022) (arguing that Maxwell
+improperly conflates the first two steps of the right to access
+analysis and that summary judgment filings for mooted motions are
+judicial documents because of potential relevancy to judicial
+function), Dawson v. Merck & Co., 2021 WL 242148, at *6 (E.D.N.Y.
+7
+
+
+Document 367 Filed 07/30/24 Page 8 of 23
+Jan. 24, 2021) (documents attached to a Daubert motion deemed
+"judicial documents
+• notwithstanding settlement by the
+parties").
+After carefully considering
+these conflicting precedents,
+this Court concludes that treating the documents here at issue as
+judicial documents is the correct approach and more consistent
+with Second Circuit precedent. Although in a context different
+from summary judgment, the Second Circuit has held that an item
+may be considered a judicial document irrespective of whether any
+court has actually relied on the document in issuing a ruling. See
+1, 929 F.3d at 50. The "inquiry is only whether the documents
+are relevant
+to the performance of the judicial function, not
+whether they were relied upon." Id. The Second Circuit has also
+emphasized that relevancy in this context is measured by potential,
+not actual, effect. See id. at 49 ("A document is thus 'relevant
+to the performance of the judicial function' if it would reasonably
+have the tendency to influence a district court's ruling on a
+motion or in the exercise of its supervisory powers, without regard
+to which way the court ultimately rules or whether the document
+ultimately in fact influences the court's decision.") (emphasis in
+text); Olson v. Major League
+Baseball, 29 F.4th 59, 89 (2d Cir.
+2022)
+(same). Since only potential and not actual reliance is
+required for judicial document status, the fact that a summary
+judgment motion is never ruled on prior to settlement does not
+8
+
+
+Case 1:22-cv-10904-JSR
+Document 367 Filed 07/30/24 Page 9 of 23
+affect the judicial document status of exhibits filed in connection
+therewith.
+Cases that hold to the contrary reason that, even if the items
+may have been judicial documents when filed, they lose this status
+once a
+settlement
+has taken place. This is because the "Article
+III's judicial power" only extends to "actual controversies
+arising between adverse litigants," but once a case settles no
+such controversy exists. Maxwell, 2020 WL 133570, at *2; see also
+In re IBM, 2022 WL 3043220, at *2 (similar). These cases further
+reason that whatever need there may be to oversee the functioning
+of the judicial power evaporates once a case settles and no future
+ruling is possible, such that the reason for the right of access
+dissipates
+as well.
+However, this first argument "conflates the first two steps
+of the [public right to access] framework." Lohnn, 2022 WL 3359737,
+at *4. Second Circuit precedent suggests the presence of a live
+controversy only "speak[s] to the weight of the presumption rather
+than whether the documents are judicial documents in the first
+place." Id. at *15. A contrary rule cannot be squared with the
+Second Circuit's
+decision in Bernstein, which found that sealed
+pleadings
+remained judicial documents even though the case was
+mooted by settlement before any ruling on a motion to dismiss. 814
+F.3d at 142.
+9
+
+
+
+The decision in Bernstein follows from the fact that the
+purpose of the right of access is broader than just monitoring
+actual decision-making. The judicial monitoring function that the
+presumption serves
+encompasses other interests, such as the right
+of "the public [tol discern the prevalence of certain types of
+cases, the nature of the parties to particular kinds of actions,
+information about the settlement rates in different areas of law,
+and the types of materials that are likely to be sealed."
+Bernstein, 814 F.3d at 140 (citation and internal quotation marks
+omitted)); see also Dawson, 2021 WL 242148, at *5 (E.D.N.Y. Jan.
+24, 2021) ("[I]nsights into the judicial process are essential to
+the public's understanding of, and ability to monitor, the
+functioning of the judiciary, even though no actual or potential
+judicial decision-making is involved."). These other interests are
+similarly implicated by documents attached to a mooted summary
+judgment motion.
+Moreover, if settlement vitiated judicial document status, an
+oddity would arise in light of the Second Circuit's decision in
+Lugosch. In Lugosch, the court held that filings attached to
+motions for summary judgment are judicial documents and publicly
+accessible even when the motion is still pending. 435 F.3d at 121.
+If the position proposed by Staley were correct, such filings would
+retrospectively lose
+judicial document status and become
+inaccessible at any moment the case settled before a ruling. Since
+10
+
+
+
+the public would never know which cases may settle ahead of time,
+this would incentivize filing a motion to unseal the moment a
+motion for summary judgment is filed, undesirably increasing
+burdens on courts
+to address such motions while briefing is
+ongoing. And in a great number of cases the motion to unseal may
+be filed out of fear that the opportunity to do so later would be
+lost, rather than any ultimate desire for the sealed materials.
+Thus, for the foregoing reasons, the Court concludes the
+deposition excerpts here in question constitute judicial
+documents.
+2. Step Iwo: First Amendment Right of Access
+Even where an item qualifies as a judicial document, the First
+Amendment right of access attaches only where the document
+satisfies at least one of two tests. Under the first test, the
+right attaches to judicial documents that "have historically been
+open to the press and general public" and to which "public access
+plays a significant positive role in the functioning of the
+particular process in question." Lugosch, 435 F.3d at 120. Under
+the second test, the right attaches if the documents "are derived
+from or [are]
+a necessary corollary of the public capacity to
+attend the relevant proceedings." Id. If the First Amendment right
+applies, it does so with the highest weight possible and sealing
+the documents can only be justified with "specific, on-the-record
+11
+
+
+
+findings that sealing is necessary to preserve higher values and
+is narrowly tailored to achieve that aim." Id. at 124.
+Applying either test, the Second Circuit has held that "there
+exists a qualified First Amendment right of access to documents
+submitted to the court in connection with a summary judgment
+motion." Id.; see also
+929 F.3d at 47 (same) • However,
+neither the Second Circuit, nor any district court in the circuit,
+has addressed whether the First Amendment right continues to apply
+when a summary judgment motion is mooted by settlement. See, e.g.,
+Lohnn, 2022 WL 3359737, at *6 n. 4 (declining to address the question
+since the First Amendment right of access was not raised by any
+party, intervenor, or amicus). But, as mentioned above, the Fourth
+Circuit has recently addressed the question, ruling that First
+Amendment right does apply regardless of the settlement. See
+Nelnet,
+105 F.4th at 173. The Court finds the Fourth Circuit's
+reasoning persuasive and in line with Second Circuit precedent.
+According to the Fourth Circuit, "It]he First Amendment right
+of access to summary judgment materials does not depend on judicial
+resolution of the summary judgment motion or judicial reliance on
+the documents in resolving the motion." Id. at 172. This is because
+"It]he public has an interest
+in ensuring basic fairness and
+deterring official misconduct not only in the outcome of certain
+proceedings, but also in the very proceedings themselves." Id. at
+172-73. For cases that settle, "it is up to the public to decide
+12
+
+
+
+"why the case was brought (and fought) [] and what exactly was at
+stake in it,'" including the question of why the case was settled.
+Id. at 173 (quoting Mueller v. Raemisch, 740 F.3d 1128, 1135-36
+(7th Cir. 2014)). Thus, access to filings attached to mooted
+motions satisfy the second test for the First Amendment, as a
+"'necessary
+corollary' of the right to attend protected
+proceedings." Id. at 173 (quoting Hartford Courant Co. v.
+Pellegrino, 380 F.3d 83, 93 (2d Cir. 2004)) .
+This position is consistent with reasoning adopted by the
+Second Circuit. The Second Circuit has suggested that "summary
+judgment is an adjudication, and
+an adjudication is a formal act
+of government, the basis of which should, absent exceptional
+circumstances, be subject to public scrutiny." Lugosch, 435 F.3d
+at 124 (citation and internal quotation marks omitted). Since
+"nothing about [thel timing" of a ruling on summary judgment is
+relevant to whether the First Amendment right applies, id. at 121,
+it is apparent that the First Amendment right "attaches immediately
+upon [thel filing [of summary judgment papers]." Nelnet, 105 F.4th
+at 172; see also Lugosch, 435 F.3d at 122 ("[R]elevant documents
+which are submitted to, and accepted by, a court of competent
+jurisdiction in the course of adjudicatory proceedings,
+become
+documents to which the presumption of public access applies,
+framing that has nothing to do with how a court ultimately comes
+out on a motion.") (internal quotation marks omitted).
+13
+
+
+
+The Second Circuit's rule in Bernstein also weighs in favor
+of finding that the First Amendment right of access applies here.
+Pleadings in settled cases allow "the public to understand the
+activity of the
+federal courts, enhancel] the court system's
+accountability and legitimacy, and inform[l the public of matters
+of public concern." Bernstein 814 F.3d at 141. "Conversely, a
+sealed complaint leaves the public unaware that a claim has been
+leveled and that state power has been invoked-and public resources
+spent-in an effort to resolve the dispute." Id. Since "the district
+courts routinely engage in adjudicatory duties even in connection
+with complaints that are dismissed or settled, " a public right of
+access to monitor courts is warranted even where "speedy settlement
+of the claim mean[s] that the court [will] not adjudicate the
+merits of the case." Id. at 143.
+The same broad rationales apply to mooted summary judgment
+motions. Public access to documents attached to such motions allow
+for a better understanding of the courts, improving public
+perception and legitimacy, and informing the public of matters of
+concern, including how public resources are being spent. These
+documents may also help the public to understand why and how
+settlement
+was reached.
+For example, a party's review of its
+adversary's collected
+evidence and arguments after discovery may
+be sufficient incentive to force settlement.
+14
+
+
+
+Finally, the analogy between trial and summary judgment
+adjudication
+helps to understand why the presumption applies
+regardless of settlement. The First Amendment right of access to
+judicial documents
+"derived from or a necessary corollary of
+the capacity to attend the relevant proceedings." Hartford Courant
+Co. v.
+Pellegrino, 380 F.3d 83, 93 (2d Cir. 2004). "Where no
+hearing is held," as is the case for summary judgment, "access to
+written documents filed in connection with pretrial motions is
+particularly important" since the public otherwise lacks any
+ability to monitor court activity. Lugosch, 435 F.3d at 124
+(internal quotation marks omitted). If a case settles in the midst
+of trial, all exhibits introduced to that point would remain in
+the public record regardless of that fact. A summary judgment
+motion is an alternative to a resolution at trial, and so the fact
+that a
+settlement makes such a motion moot similarly should not
+affect the public's right of access to exhibits that have already
+been filed.
+For the aforementioned reasons, the Court finds the first
+Amendment right of access to apply to summary judgment filings
+regardless of whether the motion was mooted by settlement. Because
+the Court finds the First Amendment right attaches, it need not
+consider the weight of any common-law right of access to these
+documents.
+15
+
+
+
+3. Countervailing Interests to the First Amendment Right
+Since the First Amendment right applies to the three exhibits
+attached to the summary judgment motions, sealing these excerpts
+can only be justified with "specific, on-the-record findings that
+sealing is necessary to preserve higher values and is narrowly
+tailored to achieve that aim." Lugosch, 435 F.3d at 124. The
+"privacy interests of those who resist disclosure" are one such
+higher value. S.E.C. v. TheStreet.com, 273 F.3d 222, 232 (2d Cir.
+2001).
+Both Staley and Doe assert privacy interests. Staley argues
+his interest is in "keeping Doe's false and uncontested testimony
+confidential" since unsealing the excerpts would not allow him any
+"fair opportunity to respond to any accusations contained"
+therein. Staley Opp. (Dkt. 293) at 4. For her part, Doe argues
+that her identity as a survivor of sexual assault as well as her
+related psychological and emotional wellbeing overcome the First
+Amendment presumption of access. Doe Opp. (Dkt. 292) at 2-3. Upon
+particularized review of the excerpted testimony in the exhibits,
+the Court finds these interests outweigh the public right to access
+the documents in their entirety.
+Doe's privacy interest by itself warrants complete sealing of
+the three exhibits. "In determining the weight to be accorded an
+assertion of a right of privacy, courts should first consider the
+degree to which the subject matter is traditionally considered
+16
+
+
+
+private rather than public. . . . The nature and degree of injury
+must also be weighed. This will entail consideration . . . of the
+sensitivity of the information and the subject." Amodeo II, 71
+F.3d at 1051. Protecting the identity of sexual assault survivors
+and the details of their assaults is traditionally considered
+private and has been widely recognized as a compelling reason to
+limit public access to judicial documents. See, e.g.,
+V.
+Warden of Attica Corr. Facility, 2020 W 6866403, at *2 (S.D.N.Y.
+Nov. 23, 2020) ("[P]rotecting the identity of the sexual assault
+victim [l provides a compelling reason to limit such access.");
+Kemp v. Noeth, 2021 WL 1512712, at *2 (S.D.N.Y. Apr. 15, 2021)
+(same) ;
+v. Dershowitz, 2020 WL 5439623, at *2 (S.D.N.Y.
+Sept. 9, 2020) ("[Countervailing] interests are particularly acute
+given that the psychological and emotional wellbeing of survivors
+of alleged sexual
+assaults may be implicated by such a broad
+disclosure.").
+Given
+the specific, graphic detail of the alleged nonconsensual activity that Doe describes in these excerpts, the
+privacy interest Doe has in non-disclosure of her testimony is
+robust. Unsealing these documents would force Doe "to relive these
+traumatic moments from her deposition publicly, and the mere
+redaction
+of
+her name would not protect
+her
+from retraumatization." Doe Opp. (Dkt. 292) at 3. Moreover, Doe's basic
+accusation that she was
+sexually assaulted by Staley is already in
+17
+
+
+
+the public record, as is Staley's denial. The further information
+contained in the excerpts serves little value aside from
+"cater[ing] to a morbid craving for that which is sensational and
+impure," to which "Iclourts have long declined to allow public
+access." Amodeo II, 71 F.3d at 1051 (internal quotation marks
+omitted) .
+Nor would "targeted redactions of identifying information,
+rather than wholesale withholding" suffice as a narrowly tailored
+means to serving Doe's privacy interest, as the Times suggests.
+Times Reply (Dkt. 294) at 1. The Court has reviewed the relevant
+excerpts and finds that the extent of redactions needed to protect
+Doe's relevant privacy interests would render what
+remains
+of
+little value. Where privacy interests require redactions
+so
+systematic that unsealing a document is "more likely to mislead
+than I] inform the public," as
+would be the case here, sealing the
+entire document is the more appropriate course. Amodeo II, 71 E.3d
+at 1052.
+Even
+assuming, arguendo, that Doe's interests are not
+independently sufficient to overcome the First Amendment right of
+access,
+Staley's privacy interests are also compelling and would,
+alongside Doe's interests, jointly warrant keeping the exhibits
+under seal. When determining the weight of an individual's privacy
+interest,
+"[t]he
+court
+should consider the reliability of the
+information. Raw, unverified information should not be as readily
+18
+
+
+
+disclosed as matters that are verified. Similarly, a court may
+consider whether the nature of the materials is such that there is
+a fair opportunity for the subject to respond to any accusations
+contained therein." Id. at 1051.
+These
+considerations clearly militate against disclosure
+here. As Staley points out, the deposition testimony was taken
+before he was even made a party to the case, so his counsel never
+had the opportunity to cross-examine Doe about her claims. Staley
+Opp. (Dkt. 293) at 1. Indeed, a deposition of Doe by Staley's
+counsel had been scheduled at the time the case settled. Id. at 1-
+2. Thus, unsealing her deposition would leave Staley devoid of any
+opportunity to respond to any allegations contained therein.
+The Times contends that "Staley is not an innocent third party
+who somehow
+finds himself caught up in a civil case in which he
+has no real interest in the outcome." Times Reply (Dkt. 294) at 5.
+This argument, however, ignores the fact that Doe never brought
+any claim against Staley and that Staley was only brought into the
+case via a third-party complaint filed by JPMorgan. Indeed, Doe's
+original complaint did not even identify Staley by name. The Times
+also argues that Staley's interest against public disclosure of
+untested allegations is not cognizable because, if it were,
+"no
+complaint ever filed in a civil case would be public" unless
+19
+
+
+
+subject to subsequent testing. Times Reply (Dkt. 294) at 5.1 But
+any allegations in a complaint are, by their nature untested, and
+so will be taken as such by any reader. By contrast, untested
+deposition testimony is a much more serious matter with potentially
+more
+far-ranging consequences. And of course, such untested
+testimony will remain under seal only in the unusual instance,
+such as that here, where the matters discussed in the testimony
+are particularly sensitive. Finally, even if arguably Staley's
+professed interest were insufficient standing alone to preclude
+disclosure, his interest when combined with the interest of Doe
+provides more than adequate basis to keep the transcripts under
+seal.
+B. Exhibits Attached to the Motion for Class Certification
+With respect to the two exhibits filed with the motion for
+class certification,
+which do not involve Staley, Doe does not
+dispute their status as judicial documents given that the Court in
+fact ruled on the class certification motion. Doe Opp. (Dkt. 292)
+at 2. Nor does Doe dispute that a First Amendment right of access
+and/or the common law presumption of access attach. Id. Rather,
+Doe argues that her privacy interest in maintaining the secrecy of
+her identity warrants against disclosure. Id.
+1 Although the Times cites no authority to support this argument, there is some
+Second Circuit precent that is least arguably consistent with it. See Bernstein,
+814 F.3d at 143.
+20
+
+
+
+While the Court agrees Doe has a privacy interest in
+connection with these transcripts, that interest is less expansive
+than that in sealing the
+summary judgment transcripts. Unlike the
+transcripts filed with the motions for summary judgment that
+contained lurid descriptions of Doe's alleged non-consensual
+sexual relations with Staley, the transcripts that were filed with
+the parties' class certification briefing contain much more
+mundane descriptions of Doe's recruitment by Epstein. There is
+much less concern, if any, about disclosing intimate details of
+traumatic events. Further, whereas the public interest in viewing
+the summary judgment transcripts is nothing more than "a morbid
+craving for that which is sensational and impure," Amodeo II, 71
+E.3d at 1051, the public's
+interest in viewing the class
+certification transcripts extends to the reasonable desire to
+understand how Epstein's organization operated and recruited
+victims.
+Ultimately, the Court agrees that Doe's interest in
+maintaining the secrecy of her identity overcomes the First
+Amendment and common-law presumption of access, but the Court also
+find that this interest does not require complete sealing of the
+excerpts. Rather, the Court finds that redactions are capable of
+preserving Doe's anonymity while still leaving sufficient relevant
+material so as not to be misleading. See Amodeo I, 44 E.3d at 147
+(suggesting courts have power to "edit and redact a judicial
+21
+
+
+
+document in order to allow access to appropriate portions of the
+document").
+Class counsel argues that "merely redacting Jane Doe 1's name
+is not sufficient to protect her identity or privacy interests"
+because "the [elxcerpts contain intimate details about Jane Doe
+l's life that are specific to her, and whose publication could
+reveal her identity to the public and to those who harmed her who
+she fears might retaliate against her." Doe Opp. (Dkt. 292) at 3.
+The Court agrees that it is appropriate to redact more than simply
+Doe's name from the transcripts, and that other information that
+might be used to identify her,
+such as the location where Doe
+lived, should also be redacted. Similarly, portions of the
+transcripts that could be used to
+identify other victims should be
+redacted as well. But that still leaves much non-identifying
+information that can be unsealed.
+III. Conclusion
+For the reasons set forth above, the Court grants in part and
+denies in part the Times' motion to unseal. Specifically, the
+motion to unseal the exhibits submitted with the summary judgment
+motions is denied, but the motion to unseal the exhibits submitted
+with the motion for class certification is granted subject to
+redactions to preserve the anonymity of Doe and other victims.
+Class counsel is directed to, within two weeks of the date of this
+22
+
+
+Case 1:22-cv-10904-JSR Document 367 Filed 07/30/24Page 23 of 23
+Opinion,
+submit for the Court's in camera review proposed
+redactions of the relevant class certification transcripts that
+are consistent with this Opinion.
+SO ORDERED.
+New York, NY
+July 29. 2024
+23

vision-fixhub/court-05/c82cbd16e126e0de0a0f9e42e01ecbfca22a0b0349398a627a57ee3b6c77fc4f.receipt.json

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vision-fixhub/court-05/c83048590f62426533b4e20caafddc1195cce663487b89d722f40e32c60dd6ec.md

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+Case 1:22-cV-10904-JSR Document 326-43 Filed 09/08/23 Page 1 of 2
+
+
+
+Case 1:22-cV-10904-JSR Document 326-43 Filed 09/08/23 Page 2 of 2
+JPMORGAN CHASE & Co.
+EXHІBIT_5o
+vIT: Stales
+LATE: 611-3
+3
+I, RDR CAR CSR #13921
+Code of Conduct 2012
+AFFIRMATION RECORD
+I affirm chat I have reported any violations of the Code, internal firm policies, or laws or regulations applicable to the firm's
+business which i know of or suspect, as required by Section 1.5 of the Code. I understand that failure to do so can result in
+disciplinary action up to and including termination of employment.
+1 understand that the Code Is updated periodically as necessary, and that the most current version is posted on the JPMorgan
+Chase intranet.
+I acknowiege that I am a Senior-Level Empioyee* for purposes of the Code and supplemental policies. As such:
+I am required to discuss any planned transactions in JPMorgan Chase securitles, for my own account or that of any of my
+empioyee-associated accounts, with a supervisor in advance. I agree to abide by this requirement.
+I have certain responsibilities that will continue after my employment with the firm terminates, including restrictions on
+hiring or soliciting the firm's employees and soliciting the firm's customers. I agree to abide by those responsibilities after my
+employment terminates.
+If you are
+an employee in an area that requires pre-clearance of personal securities transactions and/or maintenance of your
+employee and employee-associated accounts with a designated broker, you further certify the following:
+To the extent required by personal trading policies and procedures applicable to me:
+Compilance, and
+all securities transactions for my own account, or for any of my employee-associated accounts, are being pre-cleared by
+• all of my employee and employee-associated accounts are maintained with a designated broker or will be moved to a
+designated broker within the applicable time period, except for any accounts thar have been granted a written exemption by
+Compliance.
+* A Senior-Level Employee is any employee whose (a) annual base salary rate is U55150,000 (or the local currency equivaient)
+or higher, OR (b) total annual cash compensation Is US$250,000 (or the local currency equivalent) or higher. Total annual cash
+compensation means the employee's annual base salary rate plus job/shift differentlals as of the last preceding August 1, plus
+cash earnings under any incentive plans or programs (eg. annual bonus, commissions, draws, overrides, and special
+recognition payments or incentives) that are paid to or deferred by the employee during the 12-month period ending the last
+preceding Juiy 31. it does not include overtime pay. (For US employees, total annual cash compensation is the amount used
+for medical plan purposes, as shown on the Benefits Web Center.)
+Standard ID:
+U093791
+Name: Staley. James
+Department: IB EXEC 2
+Affirmation Date: 02 Jul 2012
+A CODE AFFIRMATION BY THE ABOVE-NAMED EMPLOYEE WAS RECEIVED BY THE OFFICE OF THE SECRETARY
+
+JPM-SDNYLIT-00178378

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vision-fixhub/court-05/c848bd607ddcd5a8128fe0cb50c84ed501ccbc653326a0b428c8e2950b654e68.md

@@ -0,0 +1,739 @@
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 1 of 40
+
+
+
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23
+
+Document Produced in
+Native Format
+
+JPM-SDNYLIT-W-00026008
+
+
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 3 of 40
+1
+2
+B
+C
+Reason
+D
+Date
+E
+F
+2
+Jeffrey Epstein
+Several newspaper articles were found
+that detail the indictment of Jeffrey
+Epstein in Florida on felony charges of
+soliciting underage prostitutes.
+10/17/2006
+Retain
+4
+After internal discussions with Jes Staley.
+Mary Erdoes, Catherine Keating, John Duffy
+and Mary
+it was decided that we will
+keep Mr. Epstein solely as a banking client
+and on a 'reactive', client service basis. We
+will not proactively solicit new investment
+business from him
+5
+6
+
+
+1
+~ 00
+9
+10
+11
+12
+17
+Case 1:22-cV-10904-JSR Document 326-134 Filed 09/08/23 Page 4 of 40
+5
+B
+C
+Reason
+D
+Date
+F
+10
+==
+13
+14
+15
+16
+17
+18
+19
+20
+2
+
+
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 5 of 40
+Reason
+Date
+
+
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 6 of 40
+Item#
+Reason
+Date
+
+
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 7 of 40
+Reason
+Date
+
+
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 8 of 40
+Reason
+Date
+
+
+Case 1:22-cV-10904-JSR Document 326-134 Filed 09/08/23 Page 9 of 40
+Reason
+Date
+7
+
+
+Filed 09/08/23 Page 10 of 40
+2008
+1
+2
+T
+B
+C
+Reason
+D
+Date
+F
+3
+4
+5
+
+
+Case 1:22-cV-10904-JSR Document 326-134 Filed 09/08/23 Page 11 of 40
+B
+C
+Reason
+D
+Date
+F
+8
+9
+10
+11
+12
+13
+
+
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 12 of 40
+B
+C
+Reason
+D
+Date
+E
+F
+14
+15
+16
+17
+-
+18
+10
+
+
+19
+20
+21
+22
+23
+24
+25
+21
+Jeffrey Epstein
+Case 1:22-cV-10904-JSR Document 326-134 Filed 09/08/23 Page 13 of 40
+B
+C
+Reason
+D
+Date
+mar
+Epstein was sentanced to 12
+months in jail for solicitation of a
+prostitute and six months for
+procuring a person under the age
+of 18 for prostitution followed by
+112 months of house arrest.
+7/15/2008
+Catherine will go back to JES to tell him
+ve are uncomfortable with Epstein and
+do not want to go to Cutler for approval
+-
+-
+11
+F
+
+
+Case 1:22-cV-10904-JSR Document 326-134 Filed 09/08/23 Page 14 of 40
+11/24/2008
+Not approved.
+12
+
+
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 15 of 40
+B
+U
+Reason
+D
+Date
+E
+F
+35
+36
+37
+38
+39
+40
+41
+42
+34
+35
+36
+37
+38
+39
+13
+
+
+3
+6
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 16 of 40
+1
+ClienuProspect
+Reason
+D
+Date
+E
+G
+Follow up
+Y/N
+Follow up
+Complete
+YN
+F/U Action, due date
+-
+1
+14
+
+
+Filed 09/08/23 Page 17 of 40
+B
+Reason
+D
+Date
+G
+Follow up
+Y/N
+H
+Follow up
+Complete
+Y/N
+IF/U Action, due date
+T
+10
+1
+12
+
+
+Case 1:22-cV-10904-JSR Document 326-134 Filed 09/08/23 Page 18 of 40
+Item #l
+Reason
+D
+Date
+El
+F
+G
+Follow up
+YIN
+H
+Follow up
+Complete
+Y/N
+(FIU Action, due date
+15
+16
+17
+16
+
+
+Case 1:22-cV-10904-JSR Document 326-134 Filed 09/08/23 Page 19 of 40
+C
+Client/Prospect Category
+D
+Reason
+Date
+H
+Follow up
+Y/N
+T
+Follow up
+Complete
+YIN
+F/U Action, due date
+1
+17
+
+
+Filed 09/08/23 Page 20 of 40
+C
+Client/Prospect Category
+D
+Reason
+Date
+H
+Follow up
+Y/N
+Follow up
+Complete
+YIN
+F/U Action, due date
+-
+10
+11
+12
+-
+14
+18
+
+
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 21 of 40
+Client/Prospect Category
+Reason
+Date
+H
+Follow up
+Y/N
+T
+Follow up
+Complete
+Ell Action, due date
+15
+16
+19
+
+
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 22 of 40
+19
+C
+Client/Prospect Category
+D
+Reason
+Date
+H
+Follow up
+Y/N
+1
+Follow up
+Complete
+YIN
+FIU Action, due date
+20
+20
+
+
+Case 1:22-CV-10904-JSR Document 326-134 Filed 09/08/23 Page 23 of 40
+21
+Client/Prospect Category
+Reason
+Date
+Follow up
+YIN
+Follow up
+Complete
+YIN
+FAl Action, due date
+22
+23
+23
+T
+25
+21
+
+
+Case 1:22-cv-10904-JSR Document 326-134 |
+Filed 09/08/23 Page 24 of 40
+C
+Client/Prospect Category
+D
+Reason
+Date
+H
+Follow up
+Y/N
+Follow up
+Complete
+Y/N
+F/U Action, due date
+26
+27
+28
+29
+N
+30
+22
+
+
+Case 1:22-cV-10904-JSR Document 326-134 Filed 09/08/23 Page 25 of 40
+C
+Client/Prospect Category
+D
+Reason
+Date
+F
+1
+30
+H
+Follow up
+Y/N
+1
+Follow up
+Complete
+YN
+J
+FIU Action, due date
+31
+32
+23
+
+
+Case 1:22-cV-10904-JSR Document 326-134 Filed 09/08/23 Page 26 of 40
+-
+2
+1
+Client/Prospect Category
+Reason
+Date
+Follow up
+YIN
+Follow up
+Complete
+Y/N
+Fill Action, due date
+2
+Jeffrey Epstein
+Existing Client
+The Firm's AML Director (William
+Langford) has expressed concern
+over the possibility that Mr.
+Epstein is under investigation for
+human trafficking
+1/7/2011
+Discussions to be held with Will am and AML Ops has conducted
+Nina to determine how to approach the
+extensive research to root out
+issue with Jes Stakey, who is friends with clients involved in human
+Epstein. He needs to understand the
+trafficking. William Langford is
+potential backlash to the firm given all of requiring that if the business
+the work done to root out clients
+decides to proceed, then reinvolved in human trafficking.
+approval by Steve Cutler will be
+required.
+Y
+3
+1/28/11 - Follow up to
+see if meeting with Jes
+has taken place and
+the LOB's decision for
+re-approval.
+3/15/2011:
+Paul Morris spoke with
+JE The SBLC will not
+be renewed
+3
+1
+24
+
+
+Case 1:22-cV-10904-JSR Document 326-134 Filed 09/08/23 Page 27 of 40
+Client/Prospect Category
+Reason
+Date
+Ovicone
+H
+Follow up
+Y/N
+9
+8
+1
+Follow up
+Complete
+YIN
+F/U Action, due date
+10
+11
+12
+13
+1
+25
+
+
+Case 1:22-cV-10904-JSR Document 326-134 Filed 09/08/23 Page 28 of 40
+B
+Client/Prospect Category
+Reason
+Date
+Follow up
+YIN
+Follow up
+Complete
+YIN
+F/U Action, due date
+17
+18
+LI
+19
+21
+26
+
+
+Filed 09/08/23 Page 29 of 40
+T
+Client/Prospect Category
+Reason
+Date
+G
+Follow up
+Y/N
+Follow up
+Complete
+YIN
+F/U Action, due date
+22
+23
+22
+Jeffrey Epstein
+Existing Client - 4th follow-up
+8/4/2011
+Review with John Duffy.
+Duffy to reach out to Jes Staley and
+advise that we exit while things are a bit
+Battled
+•
+27
+
+
+Case 1:22-cV-10904-JSR Document 326-134 Filed 09/08/23 Page 30 of 40
+B
+28
+Client/Prospect Category
+Reason
+Date
+G
+H
+Follow up
+Y/N
+Follow up
+Complete
+YIN
+F/U Action, due date
+29
+-
+30
+28
+
+
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 31 of 40
+Item F
+T
+Client/Prospect Category
+Reason
+Date
+G
+H
+Follow up
+Y/N
+Follow up
+Complete
+YIN
+F/U Action, due date
+35
+8=8235
+29
+
+
+Case 1:22-CV-10904-JSR Document 326-134 Filed 09/08/23 Page 32 of 40
+Client Prospect
+Category
+ECI
+Reason
+Date
+Oncome
+Follow up
+YIN
+Follow up
+Complete
+YAL
+[FAJ Action, due date
+Reputational Risk Ctte.
+Minutes Written
+30
+
+
+Case 1:22-CV-10904-JSR Document 326-134 Filed 09/08/23 Page 33 of 40
+Client Prospect
+Category
+Reason
+Date
+Follow up
+YN
+Foles up
+Complete
+YIN
+Reputational Risk Cite.
+(FAJ Action, due date
+31
+
+
+Case 1:22-CV-10904-JSR Document 326-134 Filed 09/08/23 Page 34 of 40
+Client Prospect
+Category
+Date
+Follow up
+YIN
+Ровок up
+Complete
+YAL
+Reputational Risk Cite.
+FALL Action, due date
+32
+
+
+Case 1:22-CV-10904-JSR Document 326-134 Filed 09/08/23 Page 35 of 40
+Client Prospect
+Client Prospect
+Category
+Reason
+Date
+Follow up
+YN
+Follow up
+Complete
+YAL
+FAJ Action, due date
+Reputational Risk Ctte.
+Minutes Written
+1
+33
+
+
+Case 1:22-CV-10904-JSR Document 326-134 Filed 09/08/23 Page 36 of 40
+Tient Prospect
+Client Prospect
+Category
+6-
+Reason
+Follow up
+YN
+Complete
+YIN
+Reputational Risk Ctte.
+FAJ Action, due date
+Minutes Written
+19
+20
+21
+1
+34
+
+
+Case 1:22-CV-10904-JSR Document 326-134 Filed 09/08/23 Page 37 of 40
+27
+D
+ECI
+Category
+Reason
+Fl
+Date
+Follow up
+Follow up
+Complete
+27
+28
+29
+30
+31
+32
+33
+34
+35
+36
+37
+38
+39
+40
+41
+35
+Reputational Risk Che.
+F/U Action, due date Minutes Written
+
+
+N
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 38 of 40
+D
+ECI
+Category
+Reason
+Date
+Follow up
+Y/N
+T
+Follow up
+Complete
+YIN
+Reputational Risk Ctte.
+F/U Action, due date Minutes Written
+T
+T
+36
+
+
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 39 of 40
+Hem #
+Client Prospect
+Category
+ECI
+Reason
+Date
+1
+Follow up
+Y/N
+Follow up
+Complete
+Reputational Risk Cite.
+FAJ Action, due date
+Minutes Written
+1
+37
+
+
+Case 1:22-cv-10904-JSR Document 326-134 Filed 09/08/23 Page 40 of 40
+Hem #
+•
+Client Prospect
+Category
+ECI
+Reason
+Date
+Follow up
+Y/N
+Follow up
+Complete
+Y/N
+Reputational Risk Ctte.
+F/U Action, due date Minutes Written
+14
+15
+38

vision-fixhub/court-05/c848bd607ddcd5a8128fe0cb50c84ed501ccbc653326a0b428c8e2950b654e68.receipt.json

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vision-fixhub/court-05/c857a7befceb042031925964d7769fab47e706bf52431cd6c487e77f6ea2a8e1.md

@@ -0,0 +1,456 @@
+Case 1:22-cv-10904-JSR Document 245-7 Filed 07/25/23 Page 1 of 9
+FILED UNDER SEAL
+
+
+
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+Case 1:22-CV-10904-JSR Document 245-7 Filed 07/25/23 Page 2 of 9
+
+
+UNITED STATES DISTRICT COURI FOR THE
+SOUTHERN DISTRICT OF NEW YORK
+CASE NUMBER: 22-CV-10904-JSR
+ACTION FOR DAMAGES
+GOVERNMENT OF THE UNITED STATES
+VIRGIN ISLANDS,
+Plaintiff,
+VS.
+JP
+CHASE BANK, N.A.,
+Defendant.
+
+VIDEO RECORDED DEPOSITION OF
+MONDAY, JULY 17, 2023
+REPORTED BY:
+DENISE D. HARPER-FORDE
+Certified Shorthand Reporter
+(CSR)
+Certified RealTime Reporter
+(CRR)
+Certified LiveNote Reporter (CLR)
+Registered Professional
+Reporter (RPR)
+Notary Public (FLORIDA)
+→ ESQUIRE
+
+
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+Case 1:22-cv-10904-JSR Document 245-7 Filed 07/25/23 Page 3 of 9
+
+just speak for what happened when I
+got there.
+So when you got there and you
+felt strongly that you
+something -
+wanted to do
+A. Uh-huh.
+-- what were the things you
+164
+did?
+A. Well, what I did first -- and
+keeping in mind that I first came, and
+I have a complete department to run,
+and there are crises going on in
+various departments. It's -- the
+department is critically understaffed,
+and there were many things.
+But what I did with respect to
+that in hearing all these things is
+first, as I indicated, I made a
+general -- you know, just an inquiry
+to find out do we have cases? Do we
+have a record of anyone complaining or
+any -- anyone complaining about seeing
+something that looked suspicious on
+Little St. James or -- or with respect
+to Jeffrey Epstein in particular.
+→ ESQUIRE
+
+
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+Case 1:22-cv-10904-JSR Document 245-7 Filed 07/25/23 Page 4 of 9
+
+And I -- but mainly with law
+enforcement.
+So I inquired with VIPD,
+you know, to see if there's
+anything,
+if they could look in their records
+and the Department of Justice.
+didn't do that with the federal
+authorities who were also there
+because they're -- you know, they're
+not going to disclose if there's a
+pending investigation or anything like
+that.
+165
+But I did not inquire with
+them, but -- and I found that
+the first - that's the first thing
+that I did and found that there was --
+there was nothing. Everything I got
+back was that they didn't have any
+record of anything.
+And so that's the first thing.
+And at that point in time, also what
+had been transpiring was not only the
+sex offender, the request that was -
+we were dealing with, but then I came
+to understand or I had the -- just say
+it was my understanding upon
+→ ESQUIRE
+
+
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+Case 1:22-CV-10904-JSR Document 245-7 Filed 07/25/23 Page 5 of 9
+
+166
+information and belief and that the
+federal authorities were investigating
+Jeffrey Epstein also, but -- and then
+later on there was
+the prosecution.
+Q. So there was a lot in that
+answer. So let's unpack it.
+A. Yeah, but to be -- you asked
+me what did I do --
+e. Sure.
+A. -- after.
+e. So you reached out to DOJ and
+the VIPD?
+A. Yes, and I --
+I. That was one thing?
+A. Yeah.
+e. And both of them came back and
+reported that there was --
+A. Right.
+e. - what?
+A. That they had seen -- in the
+records, they had not seen any reports
+of any complaints that came in. That
+would be something that, you know, of
+course complaints that came in
+regarding sexual assault trafficking
+→ ESQUIRE
+
+
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+Case 1:22-cv-10904-JSR Document 245-7 Filed 07/25/23 Page 6 of 9
+
+167
+or, you know, that sort of thing would
+have been going on on the island.
+e. And then what did you do after
+you found out it came back that there
+were no complaints?
+A. I just -- well, I guess
+personally I didn't -- well, what I
+did was at that point in time, I just
+started to really read a lot of the --
+of the reports, and it's -- it's news
+media reports.
+Which is fairly hearsay to
+hear - to just get the gist of what
+is being said even though I know that
+you can't - I can't just rely on -
+on news media. I can't do that.
+You know, it's rumor,
+innuendo. But to see where they're
+getting this information from and
+what's happening because it became
+even more of a curiosity for me and
+thinking this is something we -- we
+got to do something about, you know.
+I don't know what happened
+then, but I can't sit here and hear
+→ ESQUIRE
+
+
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+Case 1:22-cv-10904-JSR Document 245-7 Filed 07/25/23 Page 7 of 9
+
+168
+that all this happened, especially
+when under our statutes, sexual
+assaults and -- and child abuse are --
+have no statute of limitations.
+So it wouldn't have been too
+late to do anything if we had solid
+evidence, because I can't go by
+innuendo. I can't go by rumor.
+I
+can't go by media reports and say,
+Okay, you know, let's, you know, do an
+investigation.
+And then I was also critically
+short-staffed as well. I didn't have
+the resources either. But it was
+really where I was really
+contemplating what can be done.
+But once learning or
+understanding that the federal
+authorities were investigating
+Mr. Epstein and prosecuting
+criminally, and there was -- there
+might have been a criminal
+investigation going on.
+That is something that I would
+not do -- that it sort of preempts
+→ ESQUIRE
+
+
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+Case 1:22-cv-10904-JSR Document 245-7 Filed 07/25/23 Page 8 of 9
+
+going and doing something when once
+the federal authorities or any other
+authorities have started a criminal
+investigation or that prosecutors.
+They made the arrest. Then
+that's sort of under, I think it's
+called the First Forum Rule. It's --
+it's like in respect to the other
+forum, that you do not - you know, we
+won't go and, you know, start up a
+prosecution when there's one already
+there.
+169
+So it's been -- it pleased me
+to see that something was being done
+with law enforcement organization that
+had the resources to be able to do it.
+So once I learned that that was
+happening. Okay, then at least
+something is being done. There's a
+prosecution.
+And then I was very - you
+know, try to be in-tuned with what it
+is and what the charges were once he
+was arrested, and looking forward to
+seeing Jeffrey Epstein brought to
+→ ESQUIRE
+
+
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+Case 1:22-CV-10904-JSR Document 245-7 Filed 07/25/23 Page 9 of 9
+
+justice.
+But also hearing more about
+what happened and what part little St.
+James may have played in it.
+e. How did you learn that a
+federal investigation was being
+done?
+170
+A. I did not learn it for sure,
+but I -- I don't recall exactly how --
+there were certain questions that
+might have been asked or something
+that I -- I just sensed that there was
+an investigation going on.
+And I can't -- and it's not
+something that I could -- would even
+disclose, of course, even if I knew.
+But I sensed that one was going on.
+l. Questions asked by who?
+A. I can't tell you that. You
+know, I mean, if there -- I just don't
+recall exactly, but I think something
+I read or something and in my mind I
+said, Okay. That means that the
+federal authorities must be
+investigating.
+That was my conclusion. It
+→ ESQUIRE

vision-fixhub/court-05/c857a7befceb042031925964d7769fab47e706bf52431cd6c487e77f6ea2a8e1.receipt.json

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vision-fixhub/court-05/c8a3c4d8267ede0e30fedbf07ba6f2eeafb6683467f70344e19e8b1785ae4369.md

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+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 1 of 18
+
+
+
+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 2 of 18
+1
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+IN THE UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF NEW YORK
+GOVERNMENT OF THE UNITED STATES
+VIRGIN ISLANDS,
+Plaintiff,
+No. 22-cv-10904-JSR
+JPMORGAN BANK, N.A.,
+Defendant.
+JPMORGAN CHASE BANK, N.A.,
+Third-Party Plaintiff
+v.
+JAMES EDWARD STALEY,
+Third-Party Defendant.
+THE ORAL DEPOSITION OF ALBERT BRYAN, JR. was
+taken on the 6th day of June, 2023, at the Law Offices
+of Joel Holt, 2132 Company Street, Christiansted, St.
+Croix, U.S. Virgin Islands, between the hours of 8:42
+a.m. and 3:47 p.m. pursuant to Notice and Federal Rules
+of Civil Procedure.
+Reported by:
+DESIREE D. O
+Registered Merit Reporter
+Reporting Services
+St.
+P.O. Box 307501
+. Virgin Islands
+(340) 777-6466
+
+
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+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 3 of 18
+ALBERT BRYAN, JR. -- DIRECT
+What did Mr. Epstein say to you and what
+did you say to him as best that you recall?
+A. Well, he was just concerned about, you
+know, what we were doing if elected, you know, what
+my approach would be towards the island and towards
+permitting, my views on having certain things. Like,
+he had several docks on the island. He had problem
+getting those through DPNR as well.
+e.
+What did you tell him?
+I said, you know, I'm a very strong
+business guy. I'm not so strong on the environmental
+side. Consequently, I ended up hiring JP Oriol, the
+commissioner of DPNR, because he is the
+counterbalance to me.
+Okay. And anything else you can remember
+about that first meeting with Mr. Epstein?
+MR. ACKERMAN: Object to form.
+(By Mr. Neiman:) You could answer.
+No, I don't remember anything else.
+l. Any discussions with Mr. Epstein or his
+lawyer in connection with that meeting about him or
+people close to him contributing to your campaign?
+No.
+l. Did you ever talk to him about money?
+No.
+7
+
+
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+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 4 of 18
+ALBERT BRYAN, JR. -- DIRECT
+15
+Ms. DeJongh.
+Q. Tell me what you remember about your
+interactions with Ms. DeJongh?
+That's a very broad -- of course, she's
+the First Lady, so, or was.
+e.
+I'll break that down a little bit. Putting
+aside interactions that you had with her that didn't
+relate to her work for Mr. Epstein. So, let's just
+focus on interactions that you had with her that
+related to her work for Mr. Epstein. What do you
+recall about that?
+MR. ACKERMAN: Objection, vague.
+(By Mr. Neiman:) You can answer.
+So I worked with her -- I was the
+executive director of a non-profit, and so the only
+real interaction I had is any contributions that were
+given to the non-profit.
+So this was the job that you held between
+the time that you were head of the EDC and the time
+that you became governor?
+e.
+This is correct.
+Non-profit was what?
+Junior Achievement.
+I see. And what kind of interactions did
+you have with Mrs. deJongh related to Junior
+
+
+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 5 of 18
+ALBERT BRYAN, JR. -- DIRECT
+16
+1
+2
+3
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+7
+8
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+Achievement?
+MR. ACKERMAN: Objection.
+THE WITNESS:
+We always had
+problems satisfying their educational
+requirement of the certificate.
+So I
+would agree and recommend different
+places where she could donate the money
+that was required by their certificate.
+e.
+(By Mr. Neiman:) Okay. And this is during
+the time period when you were running Junior
+Achievement?
+Yes. That's correct.
+How about - anything else that you can
+recall interacting with Mrs. de Jongh related to
+Mr. Epstein?
+No.
+How about when you became governor, did you
+continue to interact with her related to Mr. Epstein?
+Yes. Mrs. de Jongh was instrumental in
+scheduling as well.
+e.
+scheduling what?
+Okay. So you talked to her about
+The same meeting that we had.
+Okay. Other than talking to Mrs. de Jongh
+about scheduling, anything else you can recall talking
+
+
+1
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+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 6 of 18
+ALBERT BRYAN, JR. -- DIRECT
+23
+was treated and the sentence that he was
+put to serve, I didn't think more of it.
+Q. (By Mr. Neiman:) He went to jail, right?
+Right.
+For more than a year?
+Right.
+Did that strike you as not serious?
+Well, solicitation is a serious crime, and
+solicitation with a minor is a serious crime.
+What, if anything -- we've talked about a
+report and the absence of a report. Is there anything
+else that you know of that was done by the EDC to 100k
+into the seriousness of the conduct that had led to
+this criminal conviction?
+MR. ACKERMAN: Objection.
+Foundation, vague.
+THE WITNESS: Once it was not
+effectively connected to the business
+and it wasn't in the jurisdiction of the
+Virgin Islands and he went to jail for
+it, whatever he settled with Florida was
+good for us.
+Q. (By Mr. Neiman:) All right. Now, how when
+you were the head of the EDC did you evaluate whether
+you were getting enough back in benefits from a
+
+
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+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 7 of 18
+ALBERT BRYAN, JR. -- DIRECT
+142
+A. Kind of.
+Explain.
+A. Well, that's what everybody wanted.
+That's not what we wanted individually.
+Okay. Did you end up joining forces?
+A. No.
+Q. All right. But that was sort of the
+political scuttlebutt at the time?
+Right. But we had five Democratic teams
+and no one believed any one team was strong enough to
+win outright. So they wanted to combine the forces.
+I see. And then you'll see in the fourth
+full paragraph, Mrs. de Jongh is advising Mr. Epstein,
+"Your best bet is to give wide but nominal support in
+the primary to solidify relationships, and then
+strongly support the winner of the primary going into
+the general election." Do you see that?
+Yes.
+2. Do you know whether you got support from
+Mr. Epstein in the primary?
+Yes, I do know.
+We got none. No one
+supported us. Nobody thought we would win.
+2. Did you get any contributions from anybody
+associated with Mr. Epstein for the primary.
+MR. ACKERMAN: Objection to form.
+
+
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+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 8 of 18
+ALBERT BRYAN, JR. -- DIRECT
+(By Ms. Neiman:) But this is a charity
+that you particularly invested in, right?
+If you're asking if it bought favor
+because he invested in Junior Achievement? Not
+particularly.
+e.
+I didn't ask you that. I asked you -
+A. I felt like I was helping them out more
+than they were helping me out.
+e.
+Sure. But you were helping them out by
+suggesting that they contribute to a charity that you
+were quite close to, right?
+Right. I think in the documents I was
+shown, though, I said it would be self-serving for me
+to recommend Junior Achievement. So I didn't want to
+do that, you know. Because, I mean, those are my
+people.
+e.
+Achievement?
+But then you actually suggest Junior
+Yeah, but I said it will be self-serving
+for me to do so.
+e.
+So you suggested that it will be
+self-serving?
+Yeah.
+e.
+Achievement, right?
+And then they decided to give to Junior
+166
+
+
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+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 9 of 18
+ALBERT BRYAN, JR. —- DIRECT
+167
+I don't know.
+Q. Fair enough. All right. Let's take a 1o0k
+at - well, this time I'm showing you Exhibit 20.
+This is another email exchange to Mrs. de Jongh and
+Epstein in December of 2018. Between the time when
+you were elected and began to serve as Governor,
+correct?
+(Deposition Exhibit No. 20 was
+marked for identification.)
+Eh-hmm.
+It's a tough one for the court reporter.
+Yes.
+MR. ACKERMAN: Objection to form.
+The last question, I think there were
+two questions in there.
+MR. NEIMAN: Okay.
+e.
+(By Mr. Neiman:) Now, if you look at the
+bottom of the page, you could see that Mrs. de Jongh
+writes, Good afternoon Jeffrey, Albert suggested a
+school for autistic children and Junior Achievement.
+Do you see that?
+Yes.
+Autism is another issue that's personally
+important to you?
+Yes.
+
+
+1
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+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 10 of 18
+ALBERT BRYAN, JR. -- DIRECT
+168
+e.
+Okay. And which she says here that you had
+suggested this particular school and Junior
+Achievement, is that accurate?
+Yes.
+All right. And then you see that there's a
+dialogue up above about the gift, and Mr. Epstein
+agreed to 10,000 to each, do you see that?
+Where is that?
+e.
+If you look up above Ms. De Jongh's email,
+Mr. Epstein writes 10K. And then Mrs. de Jongh asked,
+10K each? And then Mr. Epstein writes, Yes. Do you
+see that?
+Yes.
+2. Do you remember whether these two charities
+actually received the donation?
+No.
+e.
+Don't remember one way or the other?
+No. I didn't follow-up. Like I said, you
+know, they have a problem meeting their public
+education commitments. So it was more of a favor to
+them than to me. Junior Achievement is pretty
+well-funded. We have a golf tournament every year
+where we raised all the money for the year. So
+that's another place where I didn't really have to
+solicit hard in order to find donations.
+
+
+1
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+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 11 of 18
+ALBERT BRYAN, JR. -- DIRECT
+As a matter of fact, my board get on me
+because I used to tell -- I used to stop raising
+money and tell, give it to somebody else because
+there's so many needing charities in the Virgin
+Islands that don't have enough money, you know,
+especially during this period.
+But one of the charities that you chose to
+suggest to Ms. De Jongh was Junior Achievement?
+Right.
+Let's take a look now at tab --
+I just want to clarify, I didn't really
+suggest Junior Achievement. In what I read, I said,
+I should suggest -- I would suggest Junior
+Achievement but that would be self-serving. So
+technically I didn't recommend Junior Achievement.
+e.
+When you're referring to what you read,
+what are you talking about?
+A document that was in my package that was
+sent to me to review.
+e.
+Okay. And that was in -- was it
+communication between who and who?
+Cecile and I, I think. I think -
+actually, no. It wasn't in a document. I read it
+here. And then I looked back and I think we shared
+in a document to you. When I looked back in my text
+169
+
+
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+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 12 of 18
+ALBERT BRYAN, JR. -- DIRECT
+173
+e.
+Will you agree that you described your
+campaign as going out and raising money for your
+inauguration?
+No, I just want -- when I'm reading this,
+I'm just saying what this document says.
+When you talked before, was there also fund
+raising going on by your campaign for the
+inauguration?
+The inaugural committee.
+Not the campaign?
+I'm not sure. I mean, remember this is
+the island. Like, this is the same people. So I
+can't say they were in the capacity of the campaign
+or - we don't have any recorded -- I don't think we
+recorded any donations to the election roll for the
+inaugural committee from the campaigns. So if the
+inaugural committee was raising money, they were
+doing it under that guise -- not the campaign was
+done.
+e.
+raising.
+Same people, different entity doing the
+Sort of the same people. We had a lot
+more people in the inaugural committee.
+Sure. Once you won, everybody wants to be
+a part of --
+
+
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+Case 1:22-CV-10904-JSR Document 283-2 Filed 08/14/23 Page 13 of 18
+ALBERT BRYAN, JR. —- DIRECT
+174
+MR. ACKERMAN: Objection.
+THE WITNESS: Absolutely.
+(By Mr. Neiman:) And what it says here
+about how you were trying to raise the money privately
+for inaugural events, that's inaccurate?
+MR. ACKERMAN: Objection to form.
+THE WITNESS: Yeah. I wasn't
+trying to raise any money. The
+inaugural committee was.
+(By Mr. Neiman:) Well, did you tell them
+don't do this?
+MR. ACKERMAN: Objection to form.
+THE WITNESS: No.
+(By Mr. Neiman:) You could have told them
+not to do it, right?
+MR. ACKERMAN: Objection to form.
+THE WITNESS: Yeah, I could have
+told them not to do it. I think the
+whole inaugural activity thing is a
+waste of money anyway. So I didn't
+really have any involvement in it.
+(By Mr. Neiman:) Well, you went to the
+events?
+e.
+I didn't have a choice.
+I mean, you could have told them I don't
+
+
+1
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+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 14 of 18
+ALBERT BRYAN -- CROSS
+280
+to happen. Especially my previous governor had a lot
+of volatile relationships.
+Were you providing special treatment to
+Mr. Epstein by meeting
+with him in person regarding
+his complaints?
+No.
+l. Did you ever provide Mr. Epstein any
+special treatment?
+No.
+Did you ever provide Mr. Epstein any
+special treatment as a result of his association with
+Ms. Kellerhals?
+No.
+Did you ever provide Mr. Epstein any
+special treatment as a result of his -- because Cecile
+de Jongh worked for him?
+No.
+e.
+How do Virgin Islands' residents go about
+setting up a meeting with you?
+A lot of people go -- some people call
+directly the 774-0001. Some people go through my
+assistant who schedule -- who does most of my
+scheduling. And most people use whoever they know
+that was on my campaign, close to me. My poor aunt,
+who is inundated with calls, my family, everybody, to
+
+
+1
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+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 15 of 18
+ALBERT BRYAN -- CROSS
+Virgin Islands?
+No. We compete with Puerto Rico who has a
+tax benefit program as well, and Puerto Rico and
+Cayman? I'm sorry, British Virgin Islands and
+Cayman. Under the current law, a lot of those
+companies -- a lot of those foreign destinations are
+still more way more advantageous than the Virgin
+Islands.
+287
+The Virgin Islands also competes itself
+because -- against itself because we also have the
+research and technology park which offers the same
+amount of benefits.
+There were documents about the cost benefit
+ratio. Do you remember those?
+Yes.
+In your experience, are there benefits to
+the Virgin Islands from the tax benefit program beyond
+those reflected in those cost benefit ratios?
+There are tremendous benefits to the
+Virgin Islands beyond the finances in the cost
+benefits program.
+e.
+So what are those other benefits to the
+Virgin Islands?
+The one thing is having our residents that
+are able to donate heavily to charitable
+
+
+1
+2
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+8
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+25
+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 16 of 18
+ALBERT BRYAN -- CROSS
+organizations. We have a lot of non-profits that
+suffer in the Virgin Islands, especially during the
+period of the Great Recession, the energy crisis and
+the closing of Hovensa.
+So those -- that money gets
+the kids that the government doesn't -- hasn't been
+able to get. The things like Little League, Junior
+Achievement, The Women's Coalition, The Men's
+Coalition. Just to name a few, those donors give to
+them. They also shore up our educational
+infrastructure.
+When we lost the refinery in 2012, it
+shuddered -- we lost a whole school because the
+refinery paid for all of the tuition for its
+supervisory staff. Those schools benefited from that
+tuition. When that benefit was taken away, those
+kids stopped going there. We had to combine schools.
+EDC programs -- the refinery exist on an
+EDC-type program. The reason why the EDC program has
+those -- we encourage those education benefits, you
+have a whole generation of Virgin Islanders that
+became lawyers and doctors as a result of l
+Hess
+funding education in the Virgin Islands.
+So we have companies like International
+Capital Management in St.
+that not only funded
+the tuition for those people's kids to go to school.
+288
+
+
+1
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+23
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+25
+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 17 of 18
+ALBERT BRYAN -- CROSS
+289
+They actually extended loan programs to their
+employees where they would give low interest loans
+for down payments.
+Our sports benefit as well too.
+Antilles School, as a result of EDC companies moving
+here and kids of those students going to the school,
+we have like one of the top ten sailing high schools
+in the nation. A lot of those kids end up going to
+schools on sailing scholarships.
+Same so with golf, basketball where EDC
+beneficiaries fund kids' trips to go to Puerto Rico
+and to the mainland to compete in tournaments.
+So there's a lot of other ways. The
+biggest way financially that's never reflected is
+while you pay, you get an income tax reduction on the
+taxes that you get through the company any revenue
+you get through the company but your worldwide income
+is taxed fully, just like everybody else in a lot
+more income comes into the Virgin Islands that way as
+well, and that's never in the cost benefit analysis.
+Do EDC beneficiaries or owners of EDC
+beneficiaries invest in the community other than in --
+by investing in educational?
+Absolutely. We have opportunities -- the
+way that we design the law, it allows for the owners
+
+
+1
+2
+3
+4
+5
+6
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+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 283-2 Filed 08/14/23 Page 18 of 18
+ALBERT BRYAN -- CROSS
+295
+e.
+So were Mr. Epstein and his companies Ms.
+Kellerhals only client?
+No.
+e.
+In your role as EDC chair and in your
+experience as a Virgin Islands' resident, did you have
+the opportunity to observe whether EDC tax
+beneficiaries paid school tuition for the children of
+their employees?
+Yes.
+And what is it that you observed?
+So in order to get -- one of the concerns,
+especially when you're bringing people back, Virgin
+Islanders back from the states, or people in city,
+high cost-of-living. So when people come, then they
+-- even if they see the salary and they say, I'm
+going to take a lump for -- I'm going to take another
+10 for the sake of moving to the Virgin Islands or
+because I want to do this job. Then once they see
+what the school tuition is for their kids, what the
+housing is, what food costs, then they kind of have a
+change of heart. So to make it more attractive, the
+EDC companies have taken on paying for tuition for
+their students and -- for their employee students as
+well as paying 100 percent of their health insurance.
+e.
+Sir, when you were on the EDC board, did

vision-fixhub/court-05/c8a3c4d8267ede0e30fedbf07ba6f2eeafb6683467f70344e19e8b1785ae4369.receipt.json

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vision-fixhub/court-05/c91410ad982b4d7889c23e33d10be8dd90dbc32838201ec98f4f02dda23111b3.md

@@ -0,0 +1,394 @@
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 1 of 15
+
+
+
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 2 of 15
+VIRGIN ISLANDS SEXUAL OFFENDER REGISTRY
+SEX OFFENDER COMPLIANCE CHECK
+Geffrey Epstein
+SSN:
+REG. #:
+NAME:
+DOB:
+RESIDENCE:
+ADDRESS:
+DATE: 01/18/3
+IS THIS ADDRESS WITHIN A ONE-MILE RADIUS OF A CHILD-CARE FACILITY, A PUBLIC SCHOOL, A
+PRIVATE SCHOOL OR A PAROCHIAL SCHOOL?
+• YES
+• NO
+IF SO, PLEASE LIST ALL FACILITIES AND/OR SCHOOLS:
+IS THERE A COMPUTER WITH INTERNET ACCESS IN THE HOME?
+EMAIL. 1:
+EMAIL 2:
+HOME PHONE:
+CELL PHONE:
+OWN:
+RENT: L
+OTHER:
+HOUSEHOLD OCCUPANTS (Name and Age):
+• YES
+WORK PHONE:
+VEHICLES: Escalade parked down by amport
+MAKE: Dodae
+MODEL: Caravan
+MAKE: Cherrolet
+MODEL:
+Silkuhan
+WORK:
+COMPANY NAME:
+ADDRESS:
+VI-JPM-000012616
+
+
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 3 of 15
+L NO
+SCHOOL:
+SCHOOL NAME:
+ADDRESS:
+WITNESS STATEMENT:
+NAME (printed):
+DATE:
+SIGNATURE:
+COMMENTS/NOTES:
+Off island until August 2013.
+TELEPHONE:
+• COMPLIANT • NOT IN COMPLIANCE • NOT LOCATED • NEEDS INVESTIGATION
+SIGNATURE:
+DATE:
+VIDOU/SOR-11
+VI-JPM-000012617
+
+
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 4 of 15
+SCHOOL:
+SCHOOL NAME:
+ADDRESS:
+WITNESS STATEMENT:
+NAME (printed):
+DATE:
+SIGNATURE:
+COMMENTS/NOTES:
+Off island until August 2013.
+TELEPHONE:
+• COMPLIANT L NOT IN COMPLIANCE L NOT LOCATED L] NEEDS INVESTIGATION
+SIGNATURE:
+DATE:
+VI-JPM-000012618
+
+
+Case 1:22-cV-10904-JSR Document 268-18 Filed 08/07/23 Page 5 of 15
+VIRGIN ISLANDS SEXUAL OFFENDER REGISTRY
+SEX OFFENDER COMPLIANCE CHECK
+NAME: Jeffrey Epstein
+DOB:
+RESIDENCE:
+ADDRESS: Little St. James
+DATE:
+2014
+SSN:
+REG. #:
+IS THIS ADDRESS WITHIN A ONE-MILE RADIUS OF A CHILD-CARE FACILITY, A PUBLIC SCHOOL, A
+PRIVATE SCHOOL OR A PAROCHIAL SCHOOL?
+• YES
+I NO
+IF SO, PLEASE LIST ALL FACILITIES AND/OR SCHOOLS:
+IS THERE A COMPUTER WITH INTERNET ACCESS IN THE HOME?
+EMAIL. *Emails on file
+EMAIL 2:
+*all
+contact #i in tile
+HOME PHONE:
+CELL PHONE:
+OWN:
+RENT:
+OTHER:
+HOUSEHOLD OCCUPANTS (Name and Age):
+2 aduet employees
+$ YES
+WORK PHONE:
+• NO
+VEHICLES: * onfile
+MAKE:
+MAKE:
+MODEL:
+MODEL:
+WORK:
+L YES
+COMPANY NAME: STC
+ADDRESS:
+Amerian Yacht Harbor
+VI-JPM-000012619
+
+
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 6 of 15
+Ef NO
+SCHOOL:
+SCHOOL NAME:
+ADDRESS:
+WITNESS STATEMENT:
+NAME (printed):
+DATE:
+SIGNATURE:
+COMMENTS/NOTES:
+Jeffrey Epsten
+TELEPHONE:
+E COMPLIANT • NOT IN COMPLIANCE LI NOT LOCATED L] NEEDS INVESTIGATION
+SIGNATURE:
+pray
+DATE:
+07/27/2014
+VI-JPM-000012620
+
+
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 7 of 15
+E NO
+SCHOOL:
+SCHOOL NAME:
+ADDRESS:
+WITNESS STATEMENT:
+NAME (printed):
+DATE:
+SIGNATURE:
+Jeffey Spoten
+COMMENTS/NOTES:
+TELEPHONE:
+EP COMPLIANT
+SIGNATURE:
+• NOT IN COMPLIANCE • NOT LOCATED • NEEDS INVESTIGATION
+roug
+DATE:
+07/27/2014
+VI-JPM-000012621
+
+
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 8 of 15
+GRIMENT BR
+VIRGIN ISLANDS SEXUAL OFFENDER REGISTRY
+SEX OFFENDER COMPLIANCE CHECK
+Celprey
+NAME:
+DOB:
+RESIDENCE:
+ADDRESS:
+Epskin
+DATE: 2015
+SSN:
+REG.#:
+LST
+IS THIS ADDRESS WITHIN A ONE-MILE RADIUS OF A CHILD-CARE FACILITY, A PUBLIC SCHOOL, A
+PRIVATE SCHOOL OR A PAROCHIAL SCHOOL?
+• YES
+• NO
+IF SO, PLEASE LIST ALL FACILITIES AND/OR SCHOOLS:
+IS THERE A COMPUTER WITH INTERNET ACCESS IN THE HOME?
+EMAIL 1:
+EMAIL 2:
+HOME PHONE:
+OWN:
+RENT:
+CELL PHONE:
+OTHER:
+HOUSEHOLD OCCUPANTS (Name and Age):
+• YES
+WORK PHONE:
+VEHICLES:
+MAKE:
+MAKE:
+WORK:
+COMPANY NAME:
+ADDRESS:
+L YES
+MODEL:
+MODEL:
+• NO
+VI-JPM-000012622
+
+
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 9 of 15
+LI NO
+SCHOOL:
+SCHOOL NAME:
+ADDRESS:
+WITNESS STATEMENT:
+NAME (printed):
+DATE:
+SIGNATURE:
+TELEPHONE:
+COMMENTS/NOTES: (000 island)
+@first
+Epstein not present on LST, + Staff gured to us entry.
+Epstein ceutacted by stapo and stapo was allamed to escort
+us an island. (limited).
+LI COMPLIANT L NOT IN COMPLIANCE • NOT LOCATED C NEEDS INVESTIGATION
+SIGNATURE:
+DATE: 07/16/15
+VI-JPM-000012623
+
+
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 10 of 15
+SCHOOL:
+SCHOOL NAME:
+ADDRESS:
+WITNESS STATEMENT:
+NAME (printed):
+DATE:
+SIGNATURE:
+TELEPHONE:
+COMMENTS/NOTES: (000
+island)
+@first
+Epstein not present on LST, + Stagg used un us entry.
+Epstein contacted by stapo and stapo was allaned to escort
+us an island. (limited).
+• COMPLIANT L NOT IN COMPLIANCE • NOT LOCATED • NEEDS INVESTIGATION
+SIGNATURE:
+DATE: 07/16/15
+VI-JPM-000012624
+
+
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 11 of 15
+CANT OR
+VIRGIN ISLANDS SEXUAL OFFENDER REGISTRY
+Amn Rediquer
+monday
+NAME:
+Jeffrey
+Epstein
+DOB:
+RESIDENCE:
+ADDRESS:
+SEX OFFENDER COMPLIANCE CHECK
+SSN:
+REG. #:
+DATE: May 13, 2016
+IS THIS ADDRESS WITHIN A ONE-MILE RADIUS OF A CHILD-CARE FACILITY, A PUBLIC SCHOOL, A
+PRIVATE SCHOOL OR A PAROCHIAL SCHOOL?
+• YES
+• NO
+IF SO, PLEASE LIST ALL FACILITIES AND/OR SCHOOLS:
+IS THERE A COMPUTER WITH INTERNET ACCESS IN THE HOME?
+EMAIL 1:
+EMAIL 2:
+HOME PHONE:
+CELL PHONE:
+OWN: L
+RENT:
+OTHER:
+HOUSEHOLD OCCUPANTS (Name and Age):
+E YES
+WORK PHONE:
+VEHICLES:
+MAKE:
+MAKE:
+WORK:
+COMPANY NAME:
+ADDRESS:
+MODEL:
+MODEL:
+VI-JPM-000012625
+
+
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 12 of 15
+SCHOOL:
+SCHOOL NAME:
+ADDRESS:
+WITNESS STATEMENT:
+¿pateri not on istand. Left earlies for lost minute tracel.
+NAME (printed):
+DATE:
+SIGNATURE:
+COMMENTS/NOTES:
+TELEPHONE:
+Veriquation not completed as Epsteri 170 intend
+COMPLIANT • NOT IN COMPLIANCE • NOT LOCATED • NEEDS INVESTIGATION
+SIGNATURE A
+Ha
+DATE: 05/13/2016
+VI-JPM-000012626
+
+
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 13 of 15
+VIRGIN ISLANDS SEXUAL OFFENDER REGISTRY
+SEX OFFENDER COMPLIANCE CHECK
+NAME:
+Seppey
+DOB:
+Epstein
+SSN:
+DATE: 07/10/18
+REG. #:
+RESIDENCE:
+ADDRESS:
+* is us denia, entry begand let
+IS THIS ADDRESS WITHIN A ONE-MILE RADIUS OF A CHILD-CARE FACILITY, A PUBLIC SCHOOL, A
+PRIVATE SCHOOL OR A PAROCHIAL SCHOOL?
+• YES
+ENO
+IF SO, PLEASE LIST ALL FACILITIES AND/OR SCHOOLS:
+IS THERE A COMPUTER WITH INTERNET ACCESS IN THE HOME?
+EMAIL 1:
+EMAIL 2:
+HOME PHONE:
+CELL PHONE: 2ld-533•3739 WORK PHONE:
+775-2595
+OWN:
+RENT:
+OTHER:
+HOUSEHOLD OCCUPANTS (Name and Age):
+Karen laduet enplanest-As Oti undran
+Bryce
+(aduet emplayer) - Age time Unknoun
+VEHICLES:
+MAKE:
+MODEL: _
+MAKE:
+WORK:
+COMPANY NAME:
+MODEL:
+• NO
+southern Trust compans
+ADDRESS:
+VI-JPM-000012627
+
+
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 14 of 15
+LI NO
+SCHOOL:
+SCHOOL NAME:
+ADDRESS:
+WITNESS STATEMENT:
+NAME (printed):
+SIGNATURE:
+Tyla apter
+COMMENTS/NOTES:
+DATE: 7/10/15
+TELEPHONE:
+L COMPLIANT LINOTIN COMPLIANCE
+SIGNATURE:
+range
+O NOT LOCATED O NEEDS INVESTIGATION
+DATE: 07/10|18
+VI-JPM-000012628
+
+
+Case 1:22-cv-10904-JSR Document 268-18 Filed 08/07/23 Page 15 of 15
+• YES
+L NO
+SCHOOL:
+SCHOOL NAME:
+ADDRESS
+WITNESS STATEMENT:
+NAME (printed):
+aptein
+DATE: 7/10/15
+SIGNATURE:
+COMMENTS/NOTES:
+TELEPHONE:
+• COMPLIANT
+SIGNATURE:
+* NOT IN COMPLIANCE L NOTLOCATED C NEEDS INVESTIGATION
+pape
+DATE:
+0710|18
+VI-JPM-000012629

vision-fixhub/court-05/c91410ad982b4d7889c23e33d10be8dd90dbc32838201ec98f4f02dda23111b3.receipt.json

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+}

vision-fixhub/court-05/c919593cfbbb6fa82505809478e4c84dc53f59e3fa9008d8efd4ba7b8b34fda1.md

@@ -0,0 +1,32 @@
+Case 1:22-cv-10904-JSR Document 328 Filed 09/13/23 Page 1 of 1
+AO 458 (Rev. 06/09) Appearance of Counsel
+UNITED STATES DISTRICT COURT
+for the
+Southern District of New York
+Government of the United States Virgin Islands
+Plaintiff
+V.
+JPMorgan Chase Bank, N.A.
+Defendant
+Case No. 22-cv-10904 (JSR)
+APPEARANCE OF COUNSEL
+To:
+The clerk of court and all parties of record
+1 am admitted or otherwise authorized to practice in this court, and I appear in this case as counsel for:
+Third Party Defendant James Edward Staley
+Date:
+09/13/2023
+s/Brian D. Linder
+Attorney's signature
+Brian D. Linder BL3581
+Printed name and bar number
+Claymaos Madison Avenue, Suite de
+Kirshner & Linder LLP
+New York, New York 10165
+Address
+linder@clayro.com
+E-mail address
+(212) 922-1080
+Telephone number
+(212) 949-8255
+FAX number

vision-fixhub/court-05/c919593cfbbb6fa82505809478e4c84dc53f59e3fa9008d8efd4ba7b8b34fda1.receipt.json

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

vision-fixhub/court-05/c9560c4aa37f26d0898aabbf612b997d97970f7225f8e4da7cb60c5371d5b274.md

@@ -0,0 +1,2436 @@
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 1 of 43
+FILED UNDER SEAL
+
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 2 of 43
+CHASE
+UNITED STATES DISTRICT COURT FOR THE
+SOUTHERN DISTRICT OF NEW YORK
+CASE NUMBER: 22-CV-10904-JSR
+ACTION FOR DAMAGES
+GOVERNMENT OF THE UNITED STATES
+VIRGIN ISLANDS,
+July 13, 2023
+Plaintiff,
+VS.
+JP
+CHASE BANK, N.A.,
+Defendant.
+VIDEO RECORDED DEPOSITION OF
+THURSDAY, JULY 13, 2023
+REPORTED BY:
+DENISE D. HARPER-FORDE
+Certified Shorthand Reporter (CSR)
+Certified RealTime Reporter
+Certified LiveNote Reporter (CLR)
+Registered Professional Reporter (RPR)
+Notary
+Public (FLORIDA)
+& ESQUIRE
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 3 of 43
+CHASE
+July 13, 2023
+11
+give specific information as to where
+he would be residing when he was not
+in one of his own homes, when he was
+out Of the country particularly or out
+of whatever it's -- away from one of
+his own homes.
+His concern was out of having
+to disclose whose residence he may
+have been staying in, and they
+expressed some apprehensions about
+making that information publicly
+available.
+e. Okay. What was your reaction
+to the various issues that his lawyers
+were raising?
+ATTORNEY ACKERMAN: Object to
+form.
+THE WITNESS: Initially my
+reaction was we would apply the law
+strictly the way the law was written.
+And so it required him, as other
+registrants, to come in and provide
+all of the information that is
+required by statute.
+(BY ATTORNEY NEIMAN) :
+& ESQUIRE
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 4 of 43
+CHASE
+July 13, 2023
+12
+l. You said that was your initial
+reaction.
+A. Yes.
+e. Did that change over time?
+A. When -- yes.
+When his lawyer
+then began to explain and provide
+justification for their requests.
+Q. And how did it change?
+A. Well, we began to consider --
+we, myself and my staff, began to
+consider the facts that they had
+brought. Because until I received the
+request from Epstein's lawyers, I did
+not know him personally or by
+reputation. I didn't know anything
+about him.
+So when the correspondence and
+information they provided indicated
+and explained that he was a --
+basically a financier, investment
+banker or something of that sort that
+required him to be very mobile and in
+and out of the territory on very short
+notice because he was in the type of
+business that required him to travel
+→ ESQUIRE
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 5 of 43
+CHASE
+July 13, 2023
+13
+frequently. Then we considered that.
+So we began to see whether or
+not the law could accommodate it.
+And, for the most part, initially it
+was determined that we could not
+accommodate the requests he was
+making.
+l. And, again, did that
+subsequently change over time?
+A. Yes.
+Q. In what way?
+A. It changed in the discretion
+was given to the Attorney General that
+provided for a relaxation of some of
+the time requirement and notice, prior
+notice requirement for his travels.
+l. Okay. Did you ultimately
+grant him the accommodations that he
+was seeking?
+A. Io my recollection, we granted
+some by - through the discretion of
+the Attorney General, we granted some
+relaxation.
+Q. Was there -- withdrawn.
+Was Mr. Epstein the first time
+→ ESQUIRE
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 6 of 43
+CHASE
+the placement of the registrant to
+particular tiers. That's my
+recollection.
+l. Uh-huh. Let's look at Exhibit
+54 for a second -- or Tab 54 for --
+for which we'll call Exhibit 3.
+(Whereupon, Defendant's
+Exhibit No. 3, Bill No.
+29-0239, was marked for
+identification)
+(BY ATTORNEY NEIMAN) :
+l. All right. Sir, do you
+recognize Exhibit 3 as the sex
+offender legislation that was passed
+in the summer of 2012?
+A. I recognize Exhibit 3 to be a
+copy of Article 7372, which shows it
+was passed in 2012.
+l. Okay. If you look at the last
+page of the exhibit, you can see the
+seal of the Governor. Do you see
+that?
+July 13, 2023
+79
+A. Yes.
+Q. And it's dated July 18th of
+2012. Do you see that?
+→ ESQUIRE
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 7 of 43
+CHASE
+July 13, 2023
+80
+A. Yes.
+l. So that's the day in which
+this bill was signed into law?
+A. Yes.
+Q. Okay. And this is a law
+you're familiar with?
+ATTORNEY ACKERMAN:
+Object to
+form.
+THE WITNESS: I used to be
+familiar.
+(BY ATTORNEY NEIMAN) :
+l. Sure. I'm not expecting you
+to remember off the top of your head
+every detail. But there was a time
+when it was part of your job to be
+familiar with this law?
+A. Yes.
+Q. Okay. And let's just take a
+look at the tiering statute, tiering
+portion of the statute just so we can
+see if we agree on how this works.
+If you turn to page 9 of the
+statute, you'll see a Section 1721B,
+Tier Defenses. Do you see that?
+A. Yes.
+→ ESQUIRE
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 8 of 43
+CHASE
+has concluded its effort to draft
+proposed legislation."
+Do you see that?
+A. Yes.
+Q. What was this task force?
+A. Well, it was a task force we
+assembled to assist us
+with drafting
+new and upgrading of our SORNA law.
+l. All right. And the article
+references a 2011 deadline for
+upgrading the law to be in compliance
+with SORNA. Do you see that?
+A. Okay. You say it here. I
+haven't seen it yet, but...
+e. What was that deadline as you
+recall it?
+A. I don't recall.
+l. All right.
+A. They may have had a deadline
+for us to be in compliance with
+Federal law. I don't remember what it
+was.
+July 13, 2023
+119
+2. And was compliance with that
+Federal law important to getting
+funding to support your registration
+→ ESQUIRE
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 9 of 43
+CHASE
+program?
+A. Yes.
+July 13, 2023
+120
+ATTORNEY ACKERMAN:
+Object to
+form.
+(BY ATTORNEY NEIMAN) :
+l. Did the Virgin Islands get its
+new legislation passed by the July
+2011 deadline?
+A. I don't recall.
+Q. We just looked at some
+legislation that was passed in the
+summer of 2012, correct?
+A. Yes.
+e. So that would be a year after
+the deadline, right?
+A. If that's what the dates
+show.
+Q. Take a look.
+A. Yeah.
+e. Do you remember why it was
+that the Virgin Islands missed the
+statutory deadline?
+A. I don't recall. We may have
+gotten an extensions, I think. I
+think we had gotten extensions on it.
+→ ESQUIRE
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 10 of 43
+CHASE
+Q. Do you know why if the statute
+was drafted by the task force in April
+of 2011, as this article indicates,
+that it didn't get passed for another
+more than a year?
+ATTORNEY ACKERMAN: Object to
+July 13, 2023
+121
+form.
+THE WITNESS:
+I don't recall
+why. You notice the - the proposed
+legislation required Federal review as
+well. So that may have been part of
+the time span as well.
+(BY ATTORNEY NEIMAN) :
+2. Do you remember that that was
+part of the time span or are you just
+guessing?
+A. No, I see reference to it in
+the article.
+l. The article says that the
+legislation will be sent to the Office
+of the Governor, the U.s. Department
+of Justice and the Virgin Islands
+legislature for adoption. Do you see
+that?
+A. Yes.
+→ ESQUIRE
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 11 of 43
+CHASE
+l. Do you know whether DoJ --
+excuse me -- whether U.S. DoJ approval
+was required before the Virgin Islands
+legislature could adopt the statute?
+A. Yes, sir.
+l. Yes, you do know or yes, it
+was required?
+A. The answer is yes, it was
+required.
+l. Okay. Do you remember there
+being any delay in getting the
+approval from the U.S. Department of
+Justice?
+July 13, 2023
+122
+A. I wouldn't say there was --
+there were back and forth between us
+and Department of Justice, adjustments
+they may have required that we may
+have had to send back up to get the
+approval.
+e. Uh-huh. Do you recall that
+being a significant source of delay in
+getting --
+A. I don't recall.
+l. - the statute passed?
+ATTORNEY ACKERMAN: Object to
+→ ESQUIRE
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 12 of 43
+CHASE
+days. Otherwise, I could not go for a
+day trip to Tortola at the last
+minute."
+July 13, 2023
+135
+Do you see that?
+A. Okay. Yes.
+l. From your point of view, sir,
+how important was it in constructing
+sex offender registration legislation
+that it permit Mr. Epstein to make
+spontaneous trips to Iortola?
+ATTORNEY ACKERMAN: Object to
+form.
+THE WITNESS: My understanding
+of the SORNA law, purpose was not to
+restrict a person's movement. It was
+to follow, to monitor the movement.
+(BY ATTORNEY NEIMAN) :
+l. Okay. Let me ask you the
+question in a slightly different way,
+sir. From your point of view -- well,
+withdrawn.
+Sir, do you think there was
+any law enforcement interest in
+structuring a sex offender
+registration law such that it would
+& ESQUIRE
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 13 of 43
+U.S. VIRGIN ISLANDS Vs JP
+CHASE
+July 13, 2023
+142
+A.
+-- and poor people.
+Q. And you - we're not talking
+about - Mr. Epstein going to Tortola
+for a day because he's a charter boat
+captain and needs to do it for his
+work. We're talking about someone who
+is expressing desire to go for
+pleasure.
+Was that important to
+facilitate in the SORNA legislation?
+A. The SORNA legislation, you
+referenced the conference that was
+held in the - working on the SORNA
+law. One of the reasons that the task
+force was assembled, which was --
+included persons from various agencies
+within the government and some private
+-- private stakeholders, was because
+our law was what I would call a
+first-generation SORNA law. And there
+hadn't been any upgrade of that law
+for quite some time.
+And there was a
+requirement the feds recognized, and
+we agreed with them, we need to
+upgrade the law. And there were --
+→ ESQUIRE
+
+
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 14 of 43
+CHASE
+A. Right. I'm --
+ATTORNEY ACKERMAN:
+July 13, 2023
+160
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Objection.
+THE WITNESS: I'm saying that
+I may have seen that -- whether what I
+saw was this Exhibit 10 I don't
+recall.
+(BY ATTORNEY NEIMAN) :
+e. Don't recall one way or the
+other?
+A. I don't recall.
+l. You were certainly involved in
+some of the discussions with
+Mr. Epstein's counsel about what
+changes they wanted to see in the
+legislation?
+ATTORNEY ACKERMAN: Objection;
+misstates prior testimony.
+THE WITNESS: What changes
+they proposed as suggestions or
+changes, yes.
+(BY ATTORNEY NEIMAN) :
+2. Okay. And then you can see on
+the first page that Ms. Carbon writes
+to Ms. Hodge on June 25th, "Attached
+→ ESQUIRE
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 15 of 43
+CHASE
+is our counterproposal."
+Do you see that?
+A. Yes.
+e. Was it important from your
+perspective to try to reach some kind
+of agreement on a proposal with
+counsel for Mr. Epstein?
+ATTORNEY ACKERMAN:
+Objection
+July 13, 2023
+161
+to form.
+THE WITNESS: It was no less
+important as how -- consideration we
+would give to any citizen that has an
+interest in pending legislation that
+we may be willing to hear from them.
+(BY ATTORNEY NEIMAN) :
+l. Uh-huh. So it's normal in
+your practice when you're considering
+criminal justice regulation to make
+sure it's agreeable to the prospective
+offenders that the legislation --
+A. We have had --
+l. - will regulate - to the
+prospective offenders that the
+legislation will regulate?
+ATTORNEY ACKERMAN:
+Objection
+→ ESQUIRE
+
+
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 16 of 43
+to form.
+CHASE
+July 13, 2023
+162
+THE WITNESS:
+We have had --
+I've had -- my experience, several
+times, in maybe legislation that is
+pending that we receive commends and
+concerns from defense counsel, whether
+it be private counsel or the Public
+Defender's Office, and we give some
+consideration to what they may be
+requesting.
+It doesn't mean we would agree
+them and put what they want in it.
+But if we feel that it does not
+obstruct the objective and efficacy of
+the legislation, we would engage in
+that discussion.
+(BY ATTORNEY NEIMAN) :
+e. So you're saying it would be
+typical for you to share back and
+forth drafts and see if you can reach
+agreement with the offenders on
+whether they like the legislation
+you're proposing?
+ATTORNEY ACKERMAN: Objection
+to form.
+→ ESQUIRE
+
+
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 17 of 43
+CHASE
+THE WITNESS: That's not what
+July 13, 2023
+163
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+I said.
+(BY ATTORNEY NEIMAN) :
+l. Okay. Would you agree that
+that's what happened here?
+A. No.
+ATTORNEY ACKERMAN:
+Objection
+to form.
+(BY ATTORNEY NEIMAN) :
+Q. There wasn't a back and forth
+with counsel for the offender?
+ATTORNEY ACKERMAN: Objection
+to form.
+(BY ATTORNEY NEIMAN) :
+e. You can answer.
+A. I had discussions back and
+forth with legal counsel.
+l. For the offender?
+A. Maria -- Maria Hodge represent
+a whole lot of different people. When
+I speak to Maria -- when I speak to
+Maria Hodge in -- in this exchange on
+this, I am extending a courtesy to a
+member of the Virgin Islands bar in
+trying to craft a legislation that
+→ ESQUIRE
+
+
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 18 of 43
+CHASE
+affects the -- the whole Virgin
+Islands, everyone in the Virgin
+Islands.
+July 13, 2023
+164
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+So that's who I'm negotiating
+with. I'm not negotiating with
+Epstein. I don't have anything with
+Epstein. I wasn't -- I had the
+exchange and proposals with Attorney
+Hodge --
+Q. All right.
+A. - who at the same time had, I
+think from - from what you show from
+Exhibit 12 -- well, I'm sorry, one of
+the exhibits, was having - was
+making - submitting her proposal to
+the legislature as well. So the
+passage of the law, I mean, it comes
+from many different sources.
+e. Yeah. Did you think Ms. Hodge
+was working for anybody other than
+Mr. Epstein?
+A. I had an exchange with
+Attorney Maria Hodge as a respected
+member of the Virgin Islands bar. And
+regardless of who she's working for, I
+→ ESQUIRE
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 19 of 43
+CHASE
+will give her the same respect.
+O. That's not what I asked you,
+July 13, 2023
+165
+sir.
+A. Well, that's what I'm telling
+you, that's how it is.
+l. Did you --
+A. That's what -- but regardless
+of who -- if Maria Hodge represents
+someone who is a murderer --
+e. Uh-huh.
+A. - and there is a legislation
+that is - that is going through that
+she has an interest that may have an
+impact with her client, I will engage
+in a discussion with her with regard
+to the law, a proposed law, as a
+courtesy and respect to her as a
+respected member of the bar.
+l. So I'm going to resist the
+urge here. I'll ask you a different
+question. Let me just make sure I
+understand who you thought Ms. Hodge
+represented in the time that you were
+having this dialogue. Am I correct
+that you understood that Ms. Hodge
+→ ESQUIRE
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 20 of 43
+CHASE
+THE WITNESS: No, I'm good.
+ATTORNEY NEIMAN: All right.
+Let's keep going then.
+ATTORNEY NEIMAN: Let's go to
+-- I'll will show you a new exhibit,
+sir.
+July 13, 2023
+187
+ATTORNEY ACKERMAN: Is this
+18?
+ATTORNEY NEIMAN: Yeah. We'll
+call this Exhibit 18.
+(Whereupon, Defendant's
+Exhibit No. 18, Letter dated
+March 14, 2019, was marked for
+identification)
+(BY ATTORNEY NEIMAN) :
+l. All right. And if you could
+turn in Exhibit 31 to the page with
+number 12480.
+A. To Exhibit 18?
+l. Exhibit 18. Yeah, I'm sorry.
+It's Exhibit 31 in my book, but it's
+Exhibit 18 for you. If you could turn
+to the page 12480 at the bottom. All
+right, sir?
+A. What page?
+I was looking at
+→ ESQUIRE
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 21 of 43
+CHASE
+July 13, 2023
+188
+the date.
+12480. Let me know when
+you're there.
+A. Okay.
+l. Okay. So this is a letter
+dated July 16th, 2012 to you from Ms.
+Hodge. Do you see that?
+A. Yes.
+l. And the topic of the letter in
+the Re line is a request pursuant to
+Bill 29-0239 for reduction/approval of
+notice procedures for travel outside
+the Virgin Islands by Jeffrey Epstein.
+Do you see that?
+A. Yes.
+l. And in the first sentence of
+the letter, Ms. Hodge thanks you for
+meeting with her and Mr. Indyke on
+Friday, July 13th, to discuss
+implementation of the new travel
+notice procedures for registered sex
+offenders.
+Do you see that?
+A. Yes.
+Q. And that's a meeting that you
+had with them actually before the
+→ ESQUIRE
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 22 of 43
+CHASE
+July 13, 2023
+189
+Governor had even signed the bill into
+law. Isn't that right?
+A. I'm sorry.
+You have a
+question?
+Q. Yeah. My question was --
+A. I'm sorry.
+e. - the meeting that you had
+with Mr. Epstein's counsel to discuss
+giving him a reduction of notice
+procedures was before the law, the new
+bill, had even been signed into law by
+the Governor, right?
+A. Yes, it appears so.
+l. Okay.
+A. Uh-huh.
+l. Do you recall that meeting?
+A. No, I do not.
+l. All right. You can see this
+is a several-page letter that they
+have submitted to you with laying out
+what they're asking for. And then if
+you turn to page 12483, you can see a
+letter from you to Ms. Hodge on July
+25th, so about nine days after her
+letter to you. Do you see that?
+→ ESQUIRE
+
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 23 of 43
+CHASE
+A. Yes. I see that.
+l. All right. And you indicate
+in -- withdrawn.
+I take it this July 25th, 2012
+letter is your response to Ms. Hodge's
+letter to you of July 16th. Fair?
+A. Yes.
+e. And what you say in your
+letter in the second paragraph is,
+quote, "It is my understanding that
+Mr. Epstein's business activities
+require him to make frequent and often
+unexpected trips out of the territory
+to United States destinations and to
+international destinations."
+Do you see that?
+A. Yes.
+l. And you say in the next
+paragraph, "Based upon your
+representation and that of Attorney
+Darren
+Indyke, we will grant the
+waiver."
+July 13, 2023
+190
+Do you see that?
+A. Yes.
+l. And then you lay out certain
+→ ESQUIRE
+
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 24 of 43
+CHASE
+conditions for the waiver, correct?
+A. Yes.
+l. Am I correct, sir, that this
+grant of a waiver,
+as you say here,
+was based on the representations of
+Ms. Hodge and Mr. Indyke and not on
+any evidence they presented to you?
+ATTORNEY ACKERMAN: Objection
+July 13, 2023
+191
+to form.
+THE WITNESS: It was based on
+the information's that they
+provided.
+(BY ATTORNEY NEIMAN) :
+2. And that information was
+what's set forth in the letter of July
+16th, correct?
+ATTORNEY ACKERMAN: Objection
+to form.
+THE WITNESS: At least that at
+minimum.
+(BY ATTORNEY NEIMAN) :
+e. Can you identify any --
+A. If there's anything else, I
+can't recall.
+e. Okay. You can't identify
+ESQUIRE
+
+
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 25 of 43
+CHASE
+July 13, 2023
+192
+anything else they provided you?
+A. I can't recall if there was
+anything else.
+Okay. All right. And then
+you can see that if you turn the page
+again to page 12485, you will see that
+you got an
+immediate letter back from
+Ms. Hodge asking for further waivers.
+You see that?
+A. Yeah.
+Q. And what Ms. Hodge writes to
+you in the first paragraph of her
+response letter is -- let's see. The
+first sentence indicates that she's
+received your letter.
+In the second
+sentence, he says, "We appreciate the
+consideration given to Mr. Epstein's
+frequent travel requirements.
+However, we still have serious
+concerns regarding what we believe are
+undue restrictions placed on
+Mr. Epstein's travel in the conduct of
+his business and professional
+activities."
+Do you see that?
+& ESQUIRE
+
+
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 26 of 43
+U.S. VIRGIN ISLANDS Vs JP
+CHASE
+July 13, 2023
+193
+A. Yes.
+Q. Can you recall anything
+specific that Ms. Hodge told you about
+the nature of Mr. Epstein's business
+and professional activities?
+A. I don't recall.
+e. And do you recall ever seeing
+any documents or any evidence from
+anyone other than his lawyers showing
+that his business and professional
+activities required frequent travel?
+A. I don't recall if I received
+anything else.
+Q. Okay. Do you recall that you
+granted the waiver that Ms. Hodge
+requested in this follow-up letter?
+A. Yes.
+e. Why did you grant it?
+A. I was satisfied with the
+representations that were made by his
+counsel; and to the extent there was
+additional materials submitted, I --
+it was sufficient for me to reconsider
+my decision.
+Q. Are you saying that there was
+→ ESQUIRE
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 27 of 43
+CHASE
+there
+were less information about his
+activities at that time --
+e. Uh-huh.
+A. -- than now.
+Q. Okay. But we saw that in the
+file of your organization, there was
+the 2010 article from The Daily Beast
+about how he had more -- that the --
+how the federal investigation had
+identified more than 40 victims.
+Remember that?
+A. That wasn't sufficient to
+July 13, 2023
+200
+me.
+l. Did the staff tell you that?
+A. I don't recall if they told me
+that.
+l. Okay. But it wouldn't have
+mattered?
+A. Would it have mattered to --
+for me to say -- to try to restrict
+him in the Virgin Islands from going
+to Los Angeles? Probably not. That's
+not my role.
+e. Okay.
+A. My role is that when he's in
+→ ESQUIRE
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 28 of 43
+CHASE
+the Virgin Islands I know where he is.
+When he's not in the Virgin Islands, I
+know where he is. That's what the
+role of our monitor, our registry was.
+Q. Okay. And you think you know
+where he is if you know what city he's
+in --
+July 13, 2023
+201
+A. If I know what city he's in --
+e. - even though you don't know
+where -- hold on. Let me finish
+asking my question.
+A. Sorry.
+e. You think it satisfied the law
+enforcement interest in knowing where
+he is if you know what city he's in?
+ATTORNEY ACKERMAN: Objection
+to form.
+THE WITNESS: It was
+satisfactory to me in 2012.
+(BY ATTORNEY NEIMAN) :
+l. Okay. Did your staff tell you
+that he had settled cases with a dozen
+women paying more than a million
+dollars each?
+A. I don't recall.
+→ ESQUIRE
+
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 29 of 43
+U.S. VIRGIN ISLANDS Vs JP
+CHASE
+it's a matter of an agent going to
+their place of residence in a car and
+making a check. It required more than
+that to go to Little St. James to
+check on him also. So we didn't have
+a planned program of how many times he
+will be checked.
+ATTORNEY NEIMAN:
+Okay.
+Let's
+take a look, if we could, at --
+COURT REPORTER: If we could
+take a quick break?
+ATTORNEY NEIMAN: Sure.
+COURT REPORTER: Thank you.
+VIDEOGRAPHER: Off the record
+July 13, 2023
+209
+at 5:12.
+(Off the record)
+(Back on the record)
+VIDEOGRAPHER: On the record.
+The time is 5:27 P.M.
+(BY ATTORNEY NEIMAN) :
+e. Good afternoon, Mr. Frazer.
+A. Good afternoon.
+l. Sir, am I correct that in
+order to enter or leave the Virgin
+Islands from the United States, you
+→ ESQUIRE
+
+
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 30 of 43
+U.S. VIRGIN ISLANDS Vs JP
+CHASE
+need to clear customs?
+A. Yes.
+l. And that's true even if you're
+flying on a private plane?
+A. Yes.
+l. As the Attorney General of the
+Virgin Islands, did you have the
+ability, if you had a law enforcement
+reason, to find out who was traveling
+on a particular plane that entered the
+Virgin Islands?
+ATTORNEY ACKERMAN: Object to
+July 13, 2023
+210
+form.
+THE WITNESS: Yes, I imagine I
+could.
+(BY ATTORNEY NEIMAN) :
+e. Did you ever try to find out
+who was traveling with Jeffrey Epstein
+on his private jet?
+A. No.
+e. All right.
+We were taking
+before the break about the monitoring
+program. I was going to show you a
+document related to that.
+ATTORNEY NEIMAN: If we could
+→ ESQUIRE
+
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 31 of 43
+CHASE
+that she worked for him.
+l. Okay. And how did you learn
+that she worked for him?
+A. I don't recall how I knew, how
+it came to my attention then. It
+didn't --
+Q. Okay.
+Your letter granting
+the discretionary waiver states
+that -- in fact, let's just pull it
+out.
+July 13, 2023
+250
+Do you have Exhibit 4 in front
+of you?
+A. Yeah.
+e. If you would turn at the
+bottom to the page that's 12263,
+please. Let me know when you have
+that in front of you.
+A. Yes.
+l. And this is one of the letters
+that you sent to Attorney Hodge
+specifying the conditions of the
+discretionary waiver that you granted
+Mr. Epstein, correct?
+A.
+Yes.
+l. Okay. And if you look at the
+→ ESQUIRE
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 32 of 43
+U.S. VIRGIN ISLANDS Vs JP
+CHASE
+third full paragraph of that letter,
+it states, "Based upon your
+representation and that of Attorney
+Indyke. "
+July 13, 2023
+251
+Did I read that correctly?
+A. Yes.
+e. And what representations were
+you referring to there?
+A. I believe you saw in the
+record several letters from Attorney
+Maria Hodge and Attorney Indyke and
+the meetings that were had. So the
+representation includes the totality
+of all of the correspondence and the
+discussions and the meetings.
+l. So if you would go to Exhibit
+5, please. I'm sorry. Nope, stick
+with Exhibit 4, and go to the page
+that is the letter that begins at
+number 12246. Let me know when
+you're there.
+A. Okay. Yes.
+l. And is this letter that begins
+at page 12246 a letter that you
+received from Mr. Indyke?
+→ ESQUIRE
+
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 33 of 43
+CHASE
+A. Yes.
+Q. And does this letter contain
+representations upon which you relied
+in exercising your discretion to make
+decisions regarding Mr. Epstein's
+notification requirements?
+A. Yes.
+l. Okay.
+A. This was included.
+l. Okay. I'm sorry. You said
+this was?
+A. Included, yes.
+l. Okay. If you would turn,
+please, to page 2 of this letter —
+A. Uh-huh.
+l. - I want to direct your
+attention to the paragraph that begins
+first. It's the first full paragraph
+on that page.
+July 13, 2023
+252
+A. Yes.
+I. Are you with me?
+A. Yes.
+l. Okay. The second -- yes. The
+second sentence of that paragraph
+reads, "Mr. Epstein has followed the
+→ ESQUIRE
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 34 of 43
+CHASE
+July 13, 2023
+253
+same procedure in the State of
+Florida, the very same jurisdiction of
+Mr. Epstein's conviction which gave
+rise to his registration requirement,
+where Mr. Epstein is permitted to
+provide E-mail notification of his
+arrival and departure."
+Did I read that correctly?
+A. Yes.
+Q. And is that a representation
+upon which you relied in formulating
+your decision --
+A. That representation --
+however, remember that I also had my
+staff to research the requirements
+from Florida and New York, the two
+particular jurisdictions that we were
+dealing with Epstein.
+l. Okay. And if you look at the
+next sentence, it reads, "Mr. Epstein
+provides E-mail notification to the
+State of New Mexico when he travels to
+and from his vacation home in that
+jurisdiction."
+Did I read that correctly?
+→ ESQUIRE
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+23
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 35 of 43
+CHASE
+A. Yes.
+Q. And is that a representation
+upon which you relied?
+A. Yes.
+e. Okay. That same sentence
+references the State of New York.
+DO
+you see that?
+A. Yes.
+l. And did you rely on Mr.
+Indyke's representations regarding the
+State of New York?
+A. That and the research that we
+had done --
+e. Okay.
+A.
+- my staff had done.
+l. If you look at the next
+paragraph, sir, the one that begins
+"Communication between the Department
+of Justice, " let me know when you're
+there?
+July 13, 2023
+254
+A. Yes.
+l. Okay. Would you please
+read - well, let me read the last
+sentence of that paragraph where Mr.
+Indyke writes, "In short, I believe,
+→ ESQUIRE
+
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 36 of 43
+CHASE
+July 13, 2023
+255
+as do the states of Florida, New
+Mexico and New York, that there is no
+public safety necessity in requiring
+Mr. Epstein to notify the Department
+in person each time he travels to or
+from the jurisdiction."
+Did I read that correctly?
+A. Yes.
+l. And is that part of the -- of
+the representations made upon which
+you relied?
+A. We took it into
+consideration.
+Q. Okay. I'll ask you a
+question, sir, while I look for this
+next document. You mentioned earlier
+that you believe there was not the
+same type of information about
+Mr. Epstein known in 2012 or available
+in 2012 as is available now. What did
+you mean by that?
+A. I think in 2012, as I
+indicated, I think 2011, at the time
+that Mr. Epstein came up on our radar
+in the sexual offender office was the
+→ ESQUIRE
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 37 of 43
+CHASE
+and the law provide for latitude for
+an exercise of discretion.
+Based on
+the totality of the
+information that
+was given to me, I made a decision
+based on that.
+l. If you would look at Exhibit
+22, please. Actually take it back.
+We can -- let's stick with Exhibit 21.
+A. Uh-huh.
+Q. There's an insinuation in
+Exhibit 21 that either you or Senator
+did one thing or said one
+thing and did another. Do you see
+that?
+July 13, 2023
+262
+A. Yes.
+e. Do you have any -- any
+suspicion as to where that suggestion
+may have come from?
+A. No, I don't. Certainly I
+don't know what -- in reference to
+what Senator
+I may have done, I
+don't know what they may be speaking
+of. In some of these it makes to, I
+suppose it's suggestion that I did
+something contrary to what I may have
+& ESQUIRE
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 38 of 43
+CHASE
+indicated previously.
+And I think
+it's kind of a vague notion on what
+may be referenced.
+July 13, 2023
+263
+Okay.
+And what is that vague
+notion?
+A. I think the meetings that they
+- the meetings that were had when we
+- you saw that Attorney
+and
+Attorney Carbon met with Maria Hodge
+and Attorney Indyke. I was off
+island. I think I may have been on
+vacation or something or at a
+conference or something. And they
+were - they met with Maria Hodge, and
+there may have been some exchange and
+some, I think, misunderstanding as to
+our agreement on language.
+And when I got back, my
+representation from me may have been
+contrary to what they may have
+misunderstood. And so where they may
+have thought we had agreement, we may
+not have had agreement on it. And
+that may be some of what they were
+talking about.
+→ ESQUIRE
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 39 of 43
+CHASE
+As to exactly what part of it,
+I don't recall what part, but I think,
+as I think
+• back, that may be some of
+what they're referring to.
+Q. Okay.
+Speaking of going on
+vacation, there was
+some testimony
+earlier today, earlier this afternoon
+about trips to Tortola.
+Do you recall
+that?
+July 13, 2023
+264
+A. Yes.
+l. Okay. Where -- how does one
+get to Tortola from the U.S. Virgin
+Islands?
+A. Take a ferry from Red Hook,
+close over here, or a ferry from
+downtown St.
+l. How long a ferry ride is it?
+A. It's about 45 minutes.
+l. How common -- or how often
+does that ferry run?
+A. The ferry runs about probably
+maybe every - probably not every
+hour. Maybe probably every - because
+you have three ferry companies.
+So probably like maybe three within
+& ESQUIRE
+
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 40 of 43
+U.S. VIRGIN ISLANDS Vs JP
+CHASE
+three-hour time of ferries leaving.
+l. Okay. And does that run --
+A. Very frequent.
+Q. Does it run seven days a
+July 13, 2023
+265
+week?
+A. Yes.
+Q. And is it -- in your
+experience as a native Virgin
+Islander, is it common for residents
+of the Virgin Islands to visit
+Tortola?
+A. Very much so.
+e. Okay. There was reference
+earlier to the U.S. Customs and Border
+Protection. Do you recall that
+testimony?
+A. Yes.
+l. And so just to be clear, when
+an individual leaves the Virgin
+Islands, that individual has to clear
+customs, correct?
+A. Yes.
+l. And is that customs check
+performed by the Government of the
+Virgin Islands?
+→ ESQUIRE
+
+
+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 41 of 43
+CHASE
+A. No, it's not.
+l. Who performs that customs
+July 13, 2023
+266
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+check?
+A. The custom check is done by
+the Federal United States Custom and
+Border Protection agency.
+l. Did the -- to your knowledge,
+did the Federal Custom and Border
+Protection agency ever advise law
+enforcement officials in the Virgin
+Islands of any suspicion or suspicious
+activity concerning Mr. Epstein's
+travels?
+A. They never informed me. I'm
+not aware they ever informed the
+Police Commissioner.
+l. Mr. Frazer, or Attorney
+Frazer --
+A. Uh-huh.
+l. - do you believe that the
+waivers that you granted in your
+discretion enabled Mr. Epstein to
+engage in sex trafficking?
+ATTORNEY NEIMAN:
+objection,
+foundation. You can answer it.
+→ ESQUIRE
+
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 42 of 43
+CHASE
+THE WITNESS:
+No, I don't
+July 13, 2023
+267
+believe so.
+(BY ATTORNEY ACKERMAN) :
+Q. And why don't you believe so?
+A. Our job was to monitor his
+presence within the territory or out
+of the territory. What he does while
+he's out of the territory we have no
+way of knowing. When he's on there --
+when he is in the territory, what he's
+doing in his home, we are not aware
+of.
+As related to your question
+you just asked, it's when he comes
+into the territory, we know he -- he
+is present in the territory by virtue
+of his registration at Department of
+Justice. Who may be -- who may have
+flew in with him on his private jet,
+the Government of the Virgin Islands
+officials would not know. U.S.
+Customs and Border Patrol would know.
+But they've never indicated that they
+had any reason, any suspicious as to
+who was coming in with him and going
+→ ESQUIRE
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+Case 1:22-cv-10904-JSR Document 245-3 Filed 07/25/23 Page 43 of 43
+CHASE
+July 13, 2023
+268
+out with him.
+So I -- you know, I don't
+believe that there was anything that
+we did that accommodated from the
+Department of Justice in the sexual
+offender office that accommodated or
+-- or in any way facilitated his
+illegal activity.
+l. Are you aware under the Virgin
+Islands SORNA Statute of a requirement
+for an offender to register in person
+at least once a year?
+A. I can't recall honestly.
+e. Okay.
+A. Well, let me think about it.
+I believe at minimum, all registrants
+are required to register at least once
+a year. Those on lower tiers may have
+to - or higher tiers have to report
+more than once a year.
+e. Do you know whether
+Mr. Epstein registered in person at
+the Department of Justice at least
+once a year?
+A. I would expect that he did. I
+→ ESQUIRE

vision-fixhub/court-05/c9560c4aa37f26d0898aabbf612b997d97970f7225f8e4da7cb60c5371d5b274.receipt.json

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