diff --git a/vision-fixhub/court-05/c71d740632db0a930c938dde436663122d7b2b287d1083cddfc4bfbede3e9a80.md b/vision-fixhub/court-05/c71d740632db0a930c938dde436663122d7b2b287d1083cddfc4bfbede3e9a80.md new file mode 100644 index 0000000000000000000000000000000000000000..84ea01fdaa2542ae609744d65a25784e26ee426d --- /dev/null +++ b/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 +"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 \ No newline at end of file diff --git a/vision-fixhub/court-05/c71d740632db0a930c938dde436663122d7b2b287d1083cddfc4bfbede3e9a80.receipt.json b/vision-fixhub/court-05/c71d740632db0a930c938dde436663122d7b2b287d1083cddfc4bfbede3e9a80.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..b3aa430ee7a72a5631e83b25f8cf51d231d51f6b --- /dev/null +++ b/vision-fixhub/court-05/c71d740632db0a930c938dde436663122d7b2b287d1083cddfc4bfbede3e9a80.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -35, + "dataset": "marble-joined", + "doc_id": "c71d740632db0a930c938dde436663122d7b2b287d1083cddfc4bfbede3e9a80", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "9c674ec002feb5f15fafe34fa22b72a3cd6ea51f995d1f60b2788ff1a397759e", + "output_sha256": "2eed16072f02c7fc84dcaba2f5bc8cd34f8bc6e142964d67a317f8eec4eb253a", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c72adc6536eb24c1dc345abd9506c205a92659794a1a6f7b9a7f6ae1dba320bf.md b/vision-fixhub/court-05/c72adc6536eb24c1dc345abd9506c205a92659794a1a6f7b9a7f6ae1dba320bf.md new file mode 100644 index 0000000000000000000000000000000000000000..8f196d14a2af43be41c07b605c49906dd2d911d3 --- /dev/null +++ b/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 \ No newline at end of file diff --git a/vision-fixhub/court-05/c72adc6536eb24c1dc345abd9506c205a92659794a1a6f7b9a7f6ae1dba320bf.receipt.json b/vision-fixhub/court-05/c72adc6536eb24c1dc345abd9506c205a92659794a1a6f7b9a7f6ae1dba320bf.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c5186e5a053512e2d3e5d85f1a74253f69ca0eef --- /dev/null +++ b/vision-fixhub/court-05/c72adc6536eb24c1dc345abd9506c205a92659794a1a6f7b9a7f6ae1dba320bf.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -2949, + "dataset": "marble-joined", + "doc_id": "c72adc6536eb24c1dc345abd9506c205a92659794a1a6f7b9a7f6ae1dba320bf", + "engine": "marble-apple-vision", + "event_count": 26, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "a1493de0e3c83eb4a9a6897d74ff19b27447a15f7dfb57827edc3698162f4111", + "output_sha256": "7dc02a12cc4d80d64600be23c58f4759648f0f95ebe46f9d2a352e731cea593f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c73e760b240d691c80061b4edd2ee3c0483df0d32fbac92457091528d74dffc0.md b/vision-fixhub/court-05/c73e760b240d691c80061b4edd2ee3c0483df0d32fbac92457091528d74dffc0.md new file mode 100644 index 0000000000000000000000000000000000000000..d53ade11054ede59dd26e057797de50cdfe8efca --- /dev/null +++ b/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 \ No newline at end of file diff --git a/vision-fixhub/court-05/c73e760b240d691c80061b4edd2ee3c0483df0d32fbac92457091528d74dffc0.receipt.json b/vision-fixhub/court-05/c73e760b240d691c80061b4edd2ee3c0483df0d32fbac92457091528d74dffc0.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..43964e6f4dd63414713206ad40a950327533072b --- /dev/null +++ b/vision-fixhub/court-05/c73e760b240d691c80061b4edd2ee3c0483df0d32fbac92457091528d74dffc0.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -256, + "dataset": "marble-joined", + "doc_id": "c73e760b240d691c80061b4edd2ee3c0483df0d32fbac92457091528d74dffc0", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "19e658728ec764873ba9665f189540d82ed61e4a5eb2a2886d251c2c71d64391", + "output_sha256": "1ab7b8c0fcaf8faa5b58b30ea74890da12440c5dbca5441eaa4db1dd56afb13b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c7579b098e29ceeeace10a3416991b17fefcc346d13f38bf57e1e39a96f4d31e.md b/vision-fixhub/court-05/c7579b098e29ceeeace10a3416991b17fefcc346d13f38bf57e1e39a96f4d31e.md new file mode 100644 index 0000000000000000000000000000000000000000..571a2688780f409241e91fafe0efcdb577925eb7 --- /dev/null +++ b/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 diff --git a/vision-fixhub/court-05/c7579b098e29ceeeace10a3416991b17fefcc346d13f38bf57e1e39a96f4d31e.receipt.json b/vision-fixhub/court-05/c7579b098e29ceeeace10a3416991b17fefcc346d13f38bf57e1e39a96f4d31e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3fd9fa8d8e8a1f4de17c8022a987abecc87ea5be --- /dev/null +++ b/vision-fixhub/court-05/c7579b098e29ceeeace10a3416991b17fefcc346d13f38bf57e1e39a96f4d31e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -45, + "dataset": "marble-joined", + "doc_id": "c7579b098e29ceeeace10a3416991b17fefcc346d13f38bf57e1e39a96f4d31e", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "477bdcb575cb71b234806976ff3c9e0a69cfa9ab6e316027ac52beae3969cc51", + "output_sha256": "10f71187f2f37e40c55034e02f760ffa5018d5205dab4c8f66c4e8fec5d55bef", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c764a83c746666613a9898793a6cb91a1e92b1eeab04e563b26db84291d3985e.md b/vision-fixhub/court-05/c764a83c746666613a9898793a6cb91a1e92b1eeab04e563b26db84291d3985e.md new file mode 100644 index 0000000000000000000000000000000000000000..83c6fb81dd031c915c2f308997b615a15940c879 --- /dev/null +++ b/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- \ No newline at end of file diff --git a/vision-fixhub/court-05/c764a83c746666613a9898793a6cb91a1e92b1eeab04e563b26db84291d3985e.receipt.json b/vision-fixhub/court-05/c764a83c746666613a9898793a6cb91a1e92b1eeab04e563b26db84291d3985e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..04ed52de29b2b39f39e14c7f42f4fe60dead3cd5 --- /dev/null +++ b/vision-fixhub/court-05/c764a83c746666613a9898793a6cb91a1e92b1eeab04e563b26db84291d3985e.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -462, + "dataset": "marble-joined", + "doc_id": "c764a83c746666613a9898793a6cb91a1e92b1eeab04e563b26db84291d3985e", + "engine": "marble-apple-vision", + "event_count": 10, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "72e2ad3c6a2cdba3d66de3f7d4d7eff3a01d69fd799b4bdc116275b88cbdab36", + "output_sha256": "29feef42b5f7d8f8a62a6f1835e17fc756cf3298b759ccf407a47bba67d5d81b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c76a12469440fedc1ea23fc8d247570b460ade8a4a0845a2730f777f911abb03.md b/vision-fixhub/court-05/c76a12469440fedc1ea23fc8d247570b460ade8a4a0845a2730f777f911abb03.md new file mode 100644 index 0000000000000000000000000000000000000000..2ade075d5b29ceffd464c2d4dfd7fb5a86e300b5 --- /dev/null +++ b/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 diff --git a/vision-fixhub/court-05/c76a12469440fedc1ea23fc8d247570b460ade8a4a0845a2730f777f911abb03.receipt.json b/vision-fixhub/court-05/c76a12469440fedc1ea23fc8d247570b460ade8a4a0845a2730f777f911abb03.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..eb489ff21eebe981bb6db62b7bbbb2d30e2e6001 --- /dev/null +++ b/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" +} diff --git a/vision-fixhub/court-05/c76a9e9cb8c8e4bad5b889ee45215ef011cdd04789a840f1ce22d98285096aba.md b/vision-fixhub/court-05/c76a9e9cb8c8e4bad5b889ee45215ef011cdd04789a840f1ce22d98285096aba.md new file mode 100644 index 0000000000000000000000000000000000000000..459c751e43e4e3bf8f944f9d31cac760310d01a9 --- /dev/null +++ b/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 diff --git a/vision-fixhub/court-05/c76a9e9cb8c8e4bad5b889ee45215ef011cdd04789a840f1ce22d98285096aba.receipt.json b/vision-fixhub/court-05/c76a9e9cb8c8e4bad5b889ee45215ef011cdd04789a840f1ce22d98285096aba.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7dfe81e764344c58e6d6d48dc5821da95d143eb6 --- /dev/null +++ b/vision-fixhub/court-05/c76a9e9cb8c8e4bad5b889ee45215ef011cdd04789a840f1ce22d98285096aba.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -72, + "dataset": "marble-joined", + "doc_id": "c76a9e9cb8c8e4bad5b889ee45215ef011cdd04789a840f1ce22d98285096aba", + "engine": "marble-apple-vision", + "event_count": 6, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "e9a6b337b00af3018aacf8e679650f34ac7b3c2b7bab409ec13d8fc71cb60d6f", + "output_sha256": "b14ae57c0111f5713dfaccf830c3a97af45f66b8ac494da7d6759fab9eb1f497", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c76fbdc26bdd94082d991351c488bd5de48c734a9e1eaeaf97e1c70fd890db76.md b/vision-fixhub/court-05/c76fbdc26bdd94082d991351c488bd5de48c734a9e1eaeaf97e1c70fd890db76.md new file mode 100644 index 0000000000000000000000000000000000000000..d3f110bec96f0e8b413299d2d53298a825cc981f --- /dev/null +++ b/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 diff --git a/vision-fixhub/court-05/c76fbdc26bdd94082d991351c488bd5de48c734a9e1eaeaf97e1c70fd890db76.receipt.json b/vision-fixhub/court-05/c76fbdc26bdd94082d991351c488bd5de48c734a9e1eaeaf97e1c70fd890db76.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..41394b7c54722373647f5894ac6b6560b4c1b4fc --- /dev/null +++ b/vision-fixhub/court-05/c76fbdc26bdd94082d991351c488bd5de48c734a9e1eaeaf97e1c70fd890db76.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "c76fbdc26bdd94082d991351c488bd5de48c734a9e1eaeaf97e1c70fd890db76", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "fc7799fa7be335b57b0a915e4d6764eccdcfba8fca8a49811b39ba2e53ba2444", + "output_sha256": "7ad395c0876b25c90d4c27fb7c22e20049d38e202d84f1b3cda6503319412eea", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c77760075c67469808ea4e0730cb1125e61d67a3d3719ec3c6f366e2399c5af1.md b/vision-fixhub/court-05/c77760075c67469808ea4e0730cb1125e61d67a3d3719ec3c6f366e2399c5af1.md new file mode 100644 index 0000000000000000000000000000000000000000..64de89eb236dd04e0cea863f231a1e48886fe1cc --- /dev/null +++ b/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 diff --git a/vision-fixhub/court-05/c77760075c67469808ea4e0730cb1125e61d67a3d3719ec3c6f366e2399c5af1.receipt.json b/vision-fixhub/court-05/c77760075c67469808ea4e0730cb1125e61d67a3d3719ec3c6f366e2399c5af1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..364b5e1918ff3889fec0dde3e8767141a0b4b65e --- /dev/null +++ b/vision-fixhub/court-05/c77760075c67469808ea4e0730cb1125e61d67a3d3719ec3c6f366e2399c5af1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -35, + "dataset": "marble-joined", + "doc_id": "c77760075c67469808ea4e0730cb1125e61d67a3d3719ec3c6f366e2399c5af1", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "a5cab8ff8bc5281724482d6737f201f8ce7a236681201943cd5454db2778ec03", + "output_sha256": "c08cb70329d58442c7737f85bca8250cc91f54d389eefa3c5e7534765f634c0b", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c77792f47111b46a6122feb8a9fdadebcf1cc60f30c75353baf2fae28f6becec.md b/vision-fixhub/court-05/c77792f47111b46a6122feb8a9fdadebcf1cc60f30c75353baf2fae28f6becec.md new file mode 100644 index 0000000000000000000000000000000000000000..f637496aa4adda9aa35a6e5c04ddf4c818f9994c --- /dev/null +++ b/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 diff --git a/vision-fixhub/court-05/c77792f47111b46a6122feb8a9fdadebcf1cc60f30c75353baf2fae28f6becec.receipt.json b/vision-fixhub/court-05/c77792f47111b46a6122feb8a9fdadebcf1cc60f30c75353baf2fae28f6becec.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..c2e3f60478d0b339954fc23428723ec0b9c55ee2 --- /dev/null +++ b/vision-fixhub/court-05/c77792f47111b46a6122feb8a9fdadebcf1cc60f30c75353baf2fae28f6becec.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -38, + "dataset": "marble-joined", + "doc_id": "c77792f47111b46a6122feb8a9fdadebcf1cc60f30c75353baf2fae28f6becec", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "529a54976c64d3bdd5a3f6ecb19b4aaf9bf3d98d13ea2fe7e6f65163f5a89da0", + "output_sha256": "d8d43603bc872d8c07df07efa289dd5541578f8d5d3222a6541f4405c422719c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c77e8d8134ffab6179c81be6e7a515b6552c36fe560f511cf319cd836caca347.md b/vision-fixhub/court-05/c77e8d8134ffab6179c81be6e7a515b6552c36fe560f511cf319cd836caca347.md new file mode 100644 index 0000000000000000000000000000000000000000..3f302fde7be966c50cdfb96602a0c7f182c224f2 --- /dev/null +++ b/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 diff --git a/vision-fixhub/court-05/c77e8d8134ffab6179c81be6e7a515b6552c36fe560f511cf319cd836caca347.receipt.json b/vision-fixhub/court-05/c77e8d8134ffab6179c81be6e7a515b6552c36fe560f511cf319cd836caca347.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e25ed0f8f54f5ccc6b873b7ac51a16489f25f4ba --- /dev/null +++ b/vision-fixhub/court-05/c77e8d8134ffab6179c81be6e7a515b6552c36fe560f511cf319cd836caca347.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -33, + "dataset": "marble-joined", + "doc_id": "c77e8d8134ffab6179c81be6e7a515b6552c36fe560f511cf319cd836caca347", + "engine": "marble-apple-vision", + "event_count": 3, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]", + "idempotent": true, + "input_sha256": "d9942d94e093750db67c0cc1dae267730c88b6d7866195056fd72993122eea02", + "output_sha256": "b9ecf884a25f546cf7d591a4cc3211ad3ef6f447d31d351bd6f02ed449f5a796", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c78c9ea41c517b57e82e79db653ba0215f8e6843122f2a7635bde6cf2421c02e.md b/vision-fixhub/court-05/c78c9ea41c517b57e82e79db653ba0215f8e6843122f2a7635bde6cf2421c02e.md new file mode 100644 index 0000000000000000000000000000000000000000..6ccf2758603de2f33e04c3e691f1e23e2ab6bca4 --- /dev/null +++ b/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 diff --git a/vision-fixhub/court-05/c78c9ea41c517b57e82e79db653ba0215f8e6843122f2a7635bde6cf2421c02e.receipt.json b/vision-fixhub/court-05/c78c9ea41c517b57e82e79db653ba0215f8e6843122f2a7635bde6cf2421c02e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..fe3e89283a0d30526b9039a110bbed92e9b5c5c3 --- /dev/null +++ b/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" +} diff --git a/vision-fixhub/court-05/c793b386a0655a5a2cd327e0b5bad2723cdaf3fdcad8eac1710f02cadfeb0344.md b/vision-fixhub/court-05/c793b386a0655a5a2cd327e0b5bad2723cdaf3fdcad8eac1710f02cadfeb0344.md new file mode 100644 index 0000000000000000000000000000000000000000..0e9c91cdfdae622bcc161b7b49161ff164a33997 --- /dev/null +++ b/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 diff --git a/vision-fixhub/court-05/c793b386a0655a5a2cd327e0b5bad2723cdaf3fdcad8eac1710f02cadfeb0344.receipt.json b/vision-fixhub/court-05/c793b386a0655a5a2cd327e0b5bad2723cdaf3fdcad8eac1710f02cadfeb0344.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3b502c9e24e2262d09ced351b5f2b3b87f986154 --- /dev/null +++ b/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" +} diff --git a/vision-fixhub/court-05/c7d6c6199a0fdc0c7631057ae525e034ddfd06c58a8f31211ccec4a9ca11e17e.md b/vision-fixhub/court-05/c7d6c6199a0fdc0c7631057ae525e034ddfd06c58a8f31211ccec4a9ca11e17e.md new file mode 100644 index 0000000000000000000000000000000000000000..cec2637466c947853a24ee134500327c62d26259 --- /dev/null +++ b/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 diff --git a/vision-fixhub/court-05/c7d6c6199a0fdc0c7631057ae525e034ddfd06c58a8f31211ccec4a9ca11e17e.receipt.json b/vision-fixhub/court-05/c7d6c6199a0fdc0c7631057ae525e034ddfd06c58a8f31211ccec4a9ca11e17e.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5eac6d2e12ae5ceb4945106a9b92eceec80c2026 --- /dev/null +++ b/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" +} diff --git a/vision-fixhub/court-05/c7f6781248e3dae0c6b0557b8a88f7a5f26afb6f72069d69d70be40f4a0450b1.md b/vision-fixhub/court-05/c7f6781248e3dae0c6b0557b8a88f7a5f26afb6f72069d69d70be40f4a0450b1.md new file mode 100644 index 0000000000000000000000000000000000000000..3ee2e57cc6dad7729c04e82773cf67a95d4fc789 --- /dev/null +++ b/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 diff --git a/vision-fixhub/court-05/c7f6781248e3dae0c6b0557b8a88f7a5f26afb6f72069d69d70be40f4a0450b1.receipt.json b/vision-fixhub/court-05/c7f6781248e3dae0c6b0557b8a88f7a5f26afb6f72069d69d70be40f4a0450b1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..39bb8ec21c6b765058805910a7f59f04a4e0e958 --- /dev/null +++ b/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" +} diff --git a/vision-fixhub/court-05/c804c2ad1f7ea7df6a12740afa2008e6b595b1c1d35b9bddad69c28a5d41b1ab.md b/vision-fixhub/court-05/c804c2ad1f7ea7df6a12740afa2008e6b595b1c1d35b9bddad69c28a5d41b1ab.md new file mode 100644 index 0000000000000000000000000000000000000000..2c385a77b6af13de87e743f054c011bbacb0ab83 --- /dev/null +++ b/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 \ No newline at end of file diff --git a/vision-fixhub/court-05/c804c2ad1f7ea7df6a12740afa2008e6b595b1c1d35b9bddad69c28a5d41b1ab.receipt.json b/vision-fixhub/court-05/c804c2ad1f7ea7df6a12740afa2008e6b595b1c1d35b9bddad69c28a5d41b1ab.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..5e5746daa2c7ae49707d1b92a3c13f0d35bb0998 --- /dev/null +++ b/vision-fixhub/court-05/c804c2ad1f7ea7df6a12740afa2008e6b595b1c1d35b9bddad69c28a5d41b1ab.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1659, + "dataset": "marble-joined", + "doc_id": "c804c2ad1f7ea7df6a12740afa2008e6b595b1c1d35b9bddad69c28a5d41b1ab", + "engine": "marble-apple-vision", + "event_count": 39, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "ad329eb3dd175cd8c919d0e212bec9441ef7bfac2022f20803ca984fde25b9f0", + "output_sha256": "c2f0b7bcca5a18b51d3c8f57b6391b7998c26704622119322c412fbc609af5d1", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c8210b4b9869cf69433b8f90e51b3255593aa7abcec00033d0c39e5bcba4dbb1.md b/vision-fixhub/court-05/c8210b4b9869cf69433b8f90e51b3255593aa7abcec00033d0c39e5bcba4dbb1.md new file mode 100644 index 0000000000000000000000000000000000000000..6235cdb0428debab6a1cc5a1aeff574465d5ee9e --- /dev/null +++ b/vision-fixhub/court-05/c8210b4b9869cf69433b8f90e51b3255593aa7abcec00033d0c39e5bcba4dbb1.md @@ -0,0 +1,30 @@ +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. diff --git a/vision-fixhub/court-05/c8210b4b9869cf69433b8f90e51b3255593aa7abcec00033d0c39e5bcba4dbb1.receipt.json b/vision-fixhub/court-05/c8210b4b9869cf69433b8f90e51b3255593aa7abcec00033d0c39e5bcba4dbb1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..d9f32ae7d25ca7e917a3546658aed2cf965ae357 --- /dev/null +++ b/vision-fixhub/court-05/c8210b4b9869cf69433b8f90e51b3255593aa7abcec00033d0c39e5bcba4dbb1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -14, + "dataset": "marble-joined", + "doc_id": "c8210b4b9869cf69433b8f90e51b3255593aa7abcec00033d0c39e5bcba4dbb1", + "engine": "marble-apple-vision", + "event_count": 2, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]", + "idempotent": true, + "input_sha256": "4099f154234c3c2968ae90750653baea38418e42edf4735a144981ee33699e6f", + "output_sha256": "f3227b1f9e9daf452f4b4f0deb254912585238bb22b054363cdf78c508c52e76", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c82cbd16e126e0de0a0f9e42e01ecbfca22a0b0349398a627a57ee3b6c77fc4f.md b/vision-fixhub/court-05/c82cbd16e126e0de0a0f9e42e01ecbfca22a0b0349398a627a57ee3b6c77fc4f.md new file mode 100644 index 0000000000000000000000000000000000000000..20ab08f5e329101865385aa85677804ca9a418c6 --- /dev/null +++ b/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 \ No newline at end of file diff --git a/vision-fixhub/court-05/c82cbd16e126e0de0a0f9e42e01ecbfca22a0b0349398a627a57ee3b6c77fc4f.receipt.json b/vision-fixhub/court-05/c82cbd16e126e0de0a0f9e42e01ecbfca22a0b0349398a627a57ee3b6c77fc4f.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8e64ef1d7084be060e5b9ee9164af6d836f9edf9 --- /dev/null +++ b/vision-fixhub/court-05/c82cbd16e126e0de0a0f9e42e01ecbfca22a0b0349398a627a57ee3b6c77fc4f.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1215, + "dataset": "marble-joined", + "doc_id": "c82cbd16e126e0de0a0f9e42e01ecbfca22a0b0349398a627a57ee3b6c77fc4f", + "engine": "marble-apple-vision", + "event_count": 40, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "4210d1a2919e5b43ed1c9cda1c5eb7cc10da294574a14c7276ec506608740d2f", + "output_sha256": "17208bb71aaa666f497493bf8bd5a0df689525912d50080079ad7b1608ee38a7", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c83048590f62426533b4e20caafddc1195cce663487b89d722f40e32c60dd6ec.md b/vision-fixhub/court-05/c83048590f62426533b4e20caafddc1195cce663487b89d722f40e32c60dd6ec.md new file mode 100644 index 0000000000000000000000000000000000000000..9502eab536ae6dce23707498ef3d67d4119e016c --- /dev/null +++ b/vision-fixhub/court-05/c83048590f62426533b4e20caafddc1195cce663487b89d722f40e32c60dd6ec.md @@ -0,0 +1,48 @@ +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 diff --git a/vision-fixhub/court-05/c83048590f62426533b4e20caafddc1195cce663487b89d722f40e32c60dd6ec.receipt.json b/vision-fixhub/court-05/c83048590f62426533b4e20caafddc1195cce663487b89d722f40e32c60dd6ec.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..3524f6c5dd87894f105d31c375e6b10f80ec7289 --- /dev/null +++ b/vision-fixhub/court-05/c83048590f62426533b4e20caafddc1195cce663487b89d722f40e32c60dd6ec.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -46, + "dataset": "marble-joined", + "doc_id": "c83048590f62426533b4e20caafddc1195cce663487b89d722f40e32c60dd6ec", + "engine": "marble-apple-vision", + "event_count": 4, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "2bd01b3aa0a2796b4a6e3e9ef91ca5594310b3c060744c20837c6955438dab71", + "output_sha256": "9312c4630060a764ce2856705e07971d709bd1b847db09b189a1bd3295bce5a3", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c848bd607ddcd5a8128fe0cb50c84ed501ccbc653326a0b428c8e2950b654e68.md b/vision-fixhub/court-05/c848bd607ddcd5a8128fe0cb50c84ed501ccbc653326a0b428c8e2950b654e68.md new file mode 100644 index 0000000000000000000000000000000000000000..a1b087c0a1b1c4b4127b88d1705adfb69ff23025 --- /dev/null +++ b/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 \ No newline at end of file diff --git a/vision-fixhub/court-05/c848bd607ddcd5a8128fe0cb50c84ed501ccbc653326a0b428c8e2950b654e68.receipt.json b/vision-fixhub/court-05/c848bd607ddcd5a8128fe0cb50c84ed501ccbc653326a0b428c8e2950b654e68.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..a54e1861d1a16dbc98d84df5042d43e82356d6c3 --- /dev/null +++ b/vision-fixhub/court-05/c848bd607ddcd5a8128fe0cb50c84ed501ccbc653326a0b428c8e2950b654e68.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -3189, + "dataset": "marble-joined", + "doc_id": "c848bd607ddcd5a8128fe0cb50c84ed501ccbc653326a0b428c8e2950b654e68", + "engine": "marble-apple-vision", + "event_count": 45, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "fb6fb0f35a3a82ac50f3241e06f2430dc2e21fd7ef5f8fc4fe355550b8aa8b78", + "output_sha256": "fd78da9cc793cef70167a07403e947024b73b27a74022dc654a58e9061853321", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c857a7befceb042031925964d7769fab47e706bf52431cd6c487e77f6ea2a8e1.md b/vision-fixhub/court-05/c857a7befceb042031925964d7769fab47e706bf52431cd6c487e77f6ea2a8e1.md new file mode 100644 index 0000000000000000000000000000000000000000..7304deb2858a92bf1421c15df21804786cda54b2 --- /dev/null +++ b/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 + + + +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 245-7 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 + + +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 245-7 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 + + +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 245-7 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 + + +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 245-7 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 + + +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 245-7 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 + + +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 245-7 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 + + +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 245-7 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 + + +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 245-7 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 \ No newline at end of file diff --git a/vision-fixhub/court-05/c857a7befceb042031925964d7769fab47e706bf52431cd6c487e77f6ea2a8e1.receipt.json b/vision-fixhub/court-05/c857a7befceb042031925964d7769fab47e706bf52431cd6c487e77f6ea2a8e1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..183084c033adb0be47279129f2b728a06350c570 --- /dev/null +++ b/vision-fixhub/court-05/c857a7befceb042031925964d7769fab47e706bf52431cd6c487e77f6ea2a8e1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1159, + "dataset": "marble-joined", + "doc_id": "c857a7befceb042031925964d7769fab47e706bf52431cd6c487e77f6ea2a8e1", + "engine": "marble-apple-vision", + "event_count": 21, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "ac7ec224fc4eea635d48b37c761d86780bac90fca3f873a75efce44dcd764cbd", + "output_sha256": "14b1954d2d3979f2f17748a3d565a6750cc923e9823f19aa2a25374c257c235f", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c8a3c4d8267ede0e30fedbf07ba6f2eeafb6683467f70344e19e8b1785ae4369.md b/vision-fixhub/court-05/c8a3c4d8267ede0e30fedbf07ba6f2eeafb6683467f70344e19e8b1785ae4369.md new file mode 100644 index 0000000000000000000000000000000000000000..33c33a76edfd1737661ceb83b0482fa9e00ea109 --- /dev/null +++ b/vision-fixhub/court-05/c8a3c4d8267ede0e30fedbf07ba6f2eeafb6683467f70344e19e8b1785ae4369.md @@ -0,0 +1,969 @@ +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 +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 +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 + + +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 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 + + +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 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 +4 +5 +6 +7 +8 +9 +10 +11 +12 +13 +14 +15 +16 +17 +18 +19 +20 +21 +22 +23 +24 +25 +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 +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 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 + + +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 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. + + +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 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 + + +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 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 +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 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 +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 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 + + +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 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 -- + + +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 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 +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 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 +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 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 +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 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 +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 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 +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 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 \ No newline at end of file diff --git a/vision-fixhub/court-05/c8a3c4d8267ede0e30fedbf07ba6f2eeafb6683467f70344e19e8b1785ae4369.receipt.json b/vision-fixhub/court-05/c8a3c4d8267ede0e30fedbf07ba6f2eeafb6683467f70344e19e8b1785ae4369.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8ee9bb3bd1571d42f3f1abce9d49db5f283cdd0e --- /dev/null +++ b/vision-fixhub/court-05/c8a3c4d8267ede0e30fedbf07ba6f2eeafb6683467f70344e19e8b1785ae4369.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -393, + "dataset": "marble-joined", + "doc_id": "c8a3c4d8267ede0e30fedbf07ba6f2eeafb6683467f70344e19e8b1785ae4369", + "engine": "marble-apple-vision", + "event_count": 20, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "c3764e588e884af94b42a2b6372e7d8ef7f33f16997dc330ada7638d19c90fd6", + "output_sha256": "4ec65c717b06df42966cbf8712ec8f989adbad0d56f741426cad7a89fd0da084", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c91410ad982b4d7889c23e33d10be8dd90dbc32838201ec98f4f02dda23111b3.md b/vision-fixhub/court-05/c91410ad982b4d7889c23e33d10be8dd90dbc32838201ec98f4f02dda23111b3.md new file mode 100644 index 0000000000000000000000000000000000000000..4d4875652f8ce910a45449525b07fdb7a1001e8c --- /dev/null +++ b/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 \ No newline at end of file diff --git a/vision-fixhub/court-05/c91410ad982b4d7889c23e33d10be8dd90dbc32838201ec98f4f02dda23111b3.receipt.json b/vision-fixhub/court-05/c91410ad982b4d7889c23e33d10be8dd90dbc32838201ec98f4f02dda23111b3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..74c123bd0379897fa4ced0939279ff20338727f1 --- /dev/null +++ b/vision-fixhub/court-05/c91410ad982b4d7889c23e33d10be8dd90dbc32838201ec98f4f02dda23111b3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -1370, + "dataset": "marble-joined", + "doc_id": "c91410ad982b4d7889c23e33d10be8dd90dbc32838201ec98f4f02dda23111b3", + "engine": "marble-apple-vision", + "event_count": 17, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "fce09fe6a76d5712b3b4865d8caf075b506ce5fbd858bcb98fc21f5f56dca56c", + "output_sha256": "400d63f52146dc968f805b37b7b1acc4402ea564c5fd25ec3bf0e3adfaf1aafa", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c919593cfbbb6fa82505809478e4c84dc53f59e3fa9008d8efd4ba7b8b34fda1.md b/vision-fixhub/court-05/c919593cfbbb6fa82505809478e4c84dc53f59e3fa9008d8efd4ba7b8b34fda1.md new file mode 100644 index 0000000000000000000000000000000000000000..fa31456a9d1885afe25c76fc41ef0fa7f6b8e22e --- /dev/null +++ b/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 diff --git a/vision-fixhub/court-05/c919593cfbbb6fa82505809478e4c84dc53f59e3fa9008d8efd4ba7b8b34fda1.receipt.json b/vision-fixhub/court-05/c919593cfbbb6fa82505809478e4c84dc53f59e3fa9008d8efd4ba7b8b34fda1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..05106754bafe37c011ce89a5edc14cf948c8132f --- /dev/null +++ b/vision-fixhub/court-05/c919593cfbbb6fa82505809478e4c84dc53f59e3fa9008d8efd4ba7b8b34fda1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -12, + "dataset": "marble-joined", + "doc_id": "c919593cfbbb6fa82505809478e4c84dc53f59e3fa9008d8efd4ba7b8b34fda1", + "engine": "marble-apple-vision", + "event_count": 1, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]", + "idempotent": true, + "input_sha256": "0ee7989abf1835494ffc6fe0602a3f03b64bf94d88f475c95990b914e33d5bf4", + "output_sha256": "b703ab6aa30bc40549d91307c655738f18a6969087264d380d4d51b40353b4dd", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c9560c4aa37f26d0898aabbf612b997d97970f7225f8e4da7cb60c5371d5b274.md b/vision-fixhub/court-05/c9560c4aa37f26d0898aabbf612b997d97970f7225f8e4da7cb60c5371d5b274.md new file mode 100644 index 0000000000000000000000000000000000000000..3b83e6345594b43549ff727627bb03405694bc23 --- /dev/null +++ b/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 + + +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 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 +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 +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 +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 +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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 + + +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 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 +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 +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 + + +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 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 + + +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 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 \ No newline at end of file diff --git a/vision-fixhub/court-05/c9560c4aa37f26d0898aabbf612b997d97970f7225f8e4da7cb60c5371d5b274.receipt.json b/vision-fixhub/court-05/c9560c4aa37f26d0898aabbf612b997d97970f7225f8e4da7cb60c5371d5b274.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..8c790824c388209ec00a1d5c49486c6738780397 --- /dev/null +++ b/vision-fixhub/court-05/c9560c4aa37f26d0898aabbf612b997d97970f7225f8e4da7cb60c5371d5b274.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -4713, + "dataset": "marble-joined", + "doc_id": "c9560c4aa37f26d0898aabbf612b997d97970f7225f8e4da7cb60c5371d5b274", + "engine": "marble-apple-vision", + "event_count": 45, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "2a52d0edcb89b4fcaabb336f3bd4ff656a8071e7ef20aab304e9dd77c6ad9b8c", + "output_sha256": "429cffdf9796beb56917340d0c937a8992dc4975a4b942b0a202e98b0e336d29", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c95a4ad9533f154c9c95de8a38cdc7360864f8efdeedd984b8e5c626cf2816a1.md b/vision-fixhub/court-05/c95a4ad9533f154c9c95de8a38cdc7360864f8efdeedd984b8e5c626cf2816a1.md new file mode 100644 index 0000000000000000000000000000000000000000..b2481736a4ca8eaeee68c65db98e7535d983dc6a --- /dev/null +++ b/vision-fixhub/court-05/c95a4ad9533f154c9c95de8a38cdc7360864f8efdeedd984b8e5c626cf2816a1.md @@ -0,0 +1,68 @@ +Case 1:22-cv-10904-JSR Document 205-3 Filed 07/14/23 Page 1 of 4 + + + +Case 1:22-cv-10904-JSR Document 205-3 Filed 07/14/23 Page 2 of 4 +EXPERT REPORT OF BRIDGETTE CARR +June 16, 2023 + + +Case 1:22-cv-10904-JSR Document 205-3 Filed 07/14/23 Page 3 of 4 +K. +JPMorgan Should Implement Meaningful Injunctive Relief To Prevent +Future Participation In Sex Trafficking Ventures +The role of JPMorgan in this case is not unique. Banks are frequently used by traffickers +as tools to aid in their trafficking or to exploit their victims. In my experience and +ards. It may also include taking out loans, applying for government assistance, an +lisuse of personal identification for financial purposes.* +230. +As the National Survivor Study highlights, this type of exploitation by traffickers and +aided by financial institutions makes victims extremely vulnerable, even after their +trafficking ends, because it limits or even prevents their ability to access basic financial +tools. Trafficking victims, even after their exploitation, are twice as likely to be +unbanked in comparison with the U.S. population.389 This is consistent with my +386 In Harm's Way: How Systems Fail Human Trafficking Survivors, Survey Results from the +First National Survivor Study, Polars Project (Jan. 2023), https://polarsproject.org/wpcontent/uploads/2023/06/In-Harms-Way-How-Systems-Fail-Human-Trafficking-Survivors-by- +Polaris.pdf, at 37. +387 Id. +388 Id. +389 Id. at 38. +75 + + +Case 1:22-cv-10904-JSR Document 205-3 Filed 07/14/23 Page 4 of 4 +experiences in representing and advocating for trafficking victims and with +experience. After +I was exited by JPMorgan, she struggled to access basic banking +services. I believe, to prevent recurrence of the failures I observed, JPMorgan should +work with human trafficking experts and individuals who have been victims of +trafficking to develop special accommodations or banking products and protocols to +address the unique needs trafficking victims face after being exploited and financially +abused. This may, as the National Survivor Study suggests, include "providing access to +bank accounts without overdraft fees and penalties. +231. +To further prevent recurrence of the failures I observed, JPMorgan should review its +private banking relationship with Epstein and identify missed opportunities to prevent +human trafficking, and implement changes that could prevent such missed opportunities +from occurring in the future. This review should include participation by individuals who +have been victims of trafficking (lived experience experts) and non-law enforcement +human trafficking experts. Only a small percentage of human trafficking cases are +prosecuted in the United States. Relying solely on the perspective of law enforcement to +understand human trafficking may result in too narrow of a focus. +232. +I also believe that JPMorgan should prevent the opening of accounts in the private bank +without independent confirmation of basic identifying details from the customer. +JPMorgan should also not rely solely on a potential trafficking sponsor in opening new +accounts. +233. In my opinion, to prevent recurrence of the failures I observed, JPMorgan should +collaborate with human trafficking experts, including at least one that is not from law +enforcement and those with lived experience, to develop human trafficking training based +specifically on the unique risks of human trafficking inherent in the private banking +relationship and to commit to sharing this training within JPMorgan. +234. +In addition, I recommend that JPMorgan prohibit the participation of any employee who +has a personal relationship with a private banking client in the decision to retain or exit +that client. +235. +human trafficking experts. +390 Id. at 39. \ No newline at end of file diff --git a/vision-fixhub/court-05/c95a4ad9533f154c9c95de8a38cdc7360864f8efdeedd984b8e5c626cf2816a1.receipt.json b/vision-fixhub/court-05/c95a4ad9533f154c9c95de8a38cdc7360864f8efdeedd984b8e5c626cf2816a1.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..65e8e8e0773f0c0ed447706fe3377aed8e8ffa2d --- /dev/null +++ b/vision-fixhub/court-05/c95a4ad9533f154c9c95de8a38cdc7360864f8efdeedd984b8e5c626cf2816a1.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -210, + "dataset": "marble-joined", + "doc_id": "c95a4ad9533f154c9c95de8a38cdc7360864f8efdeedd984b8e5c626cf2816a1", + "engine": "marble-apple-vision", + "event_count": 7, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": true, + "input_sha256": "72818061158e0aad9acdc701a67b22dab574d627ad2bdf3120ca13b468a296f8", + "output_sha256": "083c5846a9d57324cafec40141ce8fa99fbbfdbb0045bfe5d4547c5c594b5f57", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c995354ef43e8deeaecaa2dfafae04a28c779d645b550f2d609ae43b04b388d7.md b/vision-fixhub/court-05/c995354ef43e8deeaecaa2dfafae04a28c779d645b550f2d609ae43b04b388d7.md new file mode 100644 index 0000000000000000000000000000000000000000..c989ba72a380be2466045902e34759892d9b46d4 --- /dev/null +++ b/vision-fixhub/court-05/c995354ef43e8deeaecaa2dfafae04a28c779d645b550f2d609ae43b04b388d7.md @@ -0,0 +1,674 @@ +Ca3811222c6×16902J39R 02ament327 Filero97239233 agae1109f13 +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904-JSR +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +MOTION FOR ISSUANCE OF LETTER OF REQUEST (LETTER ROGATORY) +NOW COMES, the Plaintiff, in the above referenced action, and moves for the Issuance of +a Letter of Request (Letter Rogatory) pursuant to F.R.C.P. 28 requesting an order requiring Cathy +Alexander, located at 7 Harmonie Crescent, Paradise Beach, Jeffreys Bay 6330, South Africa, to +do the following: +(a) Appear to have her remote deposition taken on a date to be agreed within 30 days of service +of the subpoena at a mutually convenient location in or near Jeffreys Bay; and +(b) Produce all Documents, Communications, and agreements related to her employment by +Jeffrey Epstein, including: +1. Employment and | +agreements, +2. Non-disclosure agreements, +3. All payments, in any form, received from or on behalf of Jeffrey Epstein, and +4. Al Coco air inter, Lestey Grotein, Ghiline Maxwell Bella Kirin Daphne +a/k/a +, Erika Kellerhals, Richard D. Kahn, and/or Darren K. Indyke. +1 + + +Case 11221090415 Doment37 File 0125123 PAge 20119 +As grounds for this Motion, the Plaintiff states the following: +1. The above captioned case is currently pending in the United States District Court for +the Southern District of New York. +2. Plaintiff alleges decedent Jeffrey E. Epstein ("Epstein") engaged in a criminal sexual +trafficking enterprise in the United States Virgin Islands, wherein he used his vast +wealth and property holdings and a deliberately opaque web of corporations and +companies to transport young women and girls to his privately owned islands where +they were held captive and subject to severe and extensive sexual abuse. Plaintiff +further alleges that Defendant JPMorgan Chase Bank, N.A. and its affiliates had actual +or constructive knowledge of Epstein's misconduct but nevertheless violated their +statutory duties to report suspicious transactions from accounts held by them. +3. Upon information and belief, Cathy Alexander was employed by decedent Epstein as +the house manager for his residence on Little St. James from approximately 1999 to +2007, and, as such, would have first-hand knowledge of Epstein's conduct and visitors +at Little St. James. +4. In order to prepare the case for trial, Plaintiff needs to the take the deposition of Cathy +Alexander. +WHEREFORE Plaintiff respectfully requests that this Honorable Court allow this Motion +and issue a Letter of Request (Letter Rogatory). A proposed Letter of Request (Letter Rogatory) +is attached to this Motion as Exhibit 1. +Dated: January 20, 2023 +CAROL +I ESQ. +ACTING ATTORNEY GENERAL +Is/Linda +LINDA +2 +(NYS Bar #2473403) + + +Casee11222e109004J38R Do@cumeent327 Ffileр001230223 Page 3300f19 +Admitted Pro Hac Vice +Motley Rice LIC +401 gth Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 232-5504 +Isinger@motleyrice.com +CAROL +(NYS Bar #2941300) +Admitted Pro Hac Vice +Acting Attorney General of the United States +Virgin Islands +Virgin Islands Department of Justice +34-38 Kronprindsens Gade +St. +_, U.S. Virgin Islands 00802 +Tel.: (340) 774-5666 ext. 10101 +DAVID I. ACKERMAN (NYS Bar #4110839) +Motley Rice LLC +401 9* Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 849-4962 +dackerman@motleyrice.com +PAIGE BOGGS +idmitted Pro Hac Vic +Motley Rice LLC +401 9*h Street NW, Suite 630 +Washington, DC 20004 +Tel: (202) 386-9629 +pboggs@motleyrice.com +CERTIFICATE OF SERVICE +I hereby certify that on January 20, 2023, the foregoing Plaintiff's Motion for Issuance of +Letter of Request (Letter Rogatory) was filed with the Clerk's Office using the CM/ECF system. +Notice of this filing will be sent to all parties of record by operation of, and parties may access this +filing through, the Court's CM/ECF system. +/s/Linda +Linda +3 + + +Case 1:22-CV-10904-JSR Document 321 Fifele0 023033Pagge bois + + + +Case 1:22-04-10904-JSR Document 821 Fide@ D23033 PEgg6 2b19 +TO: +LETTER OF REQUEST (LETTER ROGATORY) +Clerk of Humansdorp Magistrate Court +Humansdorp Magistrate Court +Du Plessis St. +Humansdorp 6300 South Africa +RE: Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +In the United States District Court for the Southern District of New York +Civil Action No. 1:22-cv-10904-JSR +Dear Sir/Madam: +The above-captioned civil action is pending before the undersigned Judge of the United +States District Court for the Southern District of New York. Plaintiff in the action seeks to obtain +the deposition of Cathy Alexander and production of documents in her possession. +Thank you for your courtesy in this matter. +BY THE COURT +Dated: +1/23/23 + + +Case 1:22-cv-10904-JSR +Document 821 Fifile 0 D22023PagE BofS +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904-JSR +ACTION FOR DAMAGES +JURY TRIAL DEMANDED +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +) +REQUEST FOR INTERNATIONAL JUDICIAL ASSISTANCE +(LETTERS ROGATORY) +The United States District Court for the Southern District of New York presents its +compliments to the Humansdorp Magistrate Court of South Africa, and requests international +judicial assistance to obtain evidence to be used in a civil proceeding before this Court in the above +captioned matter. +This Court requests the assistance described herein as necessary in the interests of justice. +The assistance requested is that the appropriate judicial authority of South Africa compel the +appearance of the below named individual to give evidence and produce documents. +The aforesaid mentioned individual: +Cathy Alexander +Residing at: +7 Harmonie Crescent, Paradise Beach, Jeffreys Bay 6330, South Africa +This Court requests Cathy Alexander produce all Documents, Communications, and +agreements related to her employment by Jeffrey Epstein, including: employment and | +1 + + +Case 1:22-0w-10904-JSR Document 32-1 Fifele DP3033Pagge $f01$ +agreements; non-disclosure agreements; all payments, in any form, received from or on behalf of +Jeffrey E. Epstein; and all Communications with Jeffrey E. Epstein, Ghislaine Maxwell, Bella +Klein, Daphne Wallace, Harry Beller, Lesley Grott, +a/k/a +Erika Kellerhals, Richard D. Kahn, and/or Darren K. Indyke. +FACTS +The above-captioned case is currently pending in the United States District Court for the +Southern District of New York. +2. +Plaintiff alleges decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking +enterprise in the Virgin Islands, wherein he used his vast wealth and property holdings and a +deliberately opaque web of corporations and companies to transport young women and girls to his +privately-owned islands where they were held captive and subject to severe and extensive sexual +abuse. Plaintiff further alleges that Defendant JPMorgan Chase Bank, N.A. and its affiliates had +actual or constructive knowledge of Epstein's misconduct but nevertheless violated their statutory +duties to report suspicious transactions from accounts held by them. +3. +Upon information and belief, Cathy Alexander was employed by decedent Jeffrey E. +Epstein as the house manager for his residence on Little St. James from approximately 1999 to +2007, and, as such, would have first-hand knowledge of Epstein's conduct and visitors at Little St. +James. +4. +In order to prepare the case for trial, Plaintiff needs to the take the deposition of Cathy +Alexander. +Plaintiff has previously attempted to obtain Cathy Alexander's deposition and run into +obstacles attempting to depose her. +2 + + +Case 1:22-0x-10904JSR Donument 321 Field D/Ø30/33 PRg985615 +A Subpoena to Testify at a Deposition in a Civil Action is attached hereto, requesting Cathy +Alexander appear to have her deposition taken, at a location to be determined, and produce +documents thirty days after the date she is served with the Subpoena and Letter Rogatory. +The United States District Court for the Southern District of New York is willing to provide +similar assistance to judicial authorities of South Africa. The United States District Court for the +Southern District of New York is willing to reimburse the judicial authorities for costs incurred in +executing this Letters Rogatory. +Thank you for your courtesy in this matter. +BY THE COURT +Dated: January 23 +- 2023 +JED S. RAKOFF +United States District Court +For the Southern District of New York +United States Courthouse +500 Pearl Street +New York, NY 10007 +(212) 805-0401 Telephone +3 + + +Case 1:22-0V-10904-JSR Document 82-2 Fifele 0D25023P Agge bot 9 +AO 88A (Rev. 12/20) Subpoena to Testify at a Deposition in a Civil Action +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 +Civil Action No. 1:22-cv-10904-JSR +To: +SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION +Cathy Alexander +(Name of person to whom this subpoena is directed) +• Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a +deposition to be taken in this civil action. If you are an organization, you must promptly confer in good faith with the +party serving this subpoena about the following matters, or those set forth in an attachment, and you must designate one +or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about +these matters: +Place: A mutually convenient location in or near +Jeffreys Bay, South Africa (remotely) +Date and Time: +Within 30 days after service of Subpoena +The deposition will be recorded by this method: +videographically and stenographically +• Production: You, or your representatives, must also bring with you to the deposition the following documents, +electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the +material: See attached Exhibit A. +The following provisions of Fed. R. Civ. P. 45 are attached - Rule 45(c), relating to the place of compliance; +Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to +respond to this subpoena and the potential consequences of not doing so. +Date: +01/20/2023 +CLERK OF COURT +OR +Signature of Clerk or Deputy Clerk +Is/Linda l +Attorney's signature +The name, address, e-mail address, and telephone number of the attorney representing (name of party) +Plaintiff, +Government of the United States Virgin Islands +Linda +I Motley Rice LIC, 451 9in Street NW, Suite 630, Washington, DC 21804, (202) Ses-tze subpoena, are: +Isinger@motleyrice.com +Notice to the person who issues or requests this subpoena +If this subpoena commands the production of documents, electronically stored information, or tangible things before +trial, a notice and a copy of the subpoena must be served on each party in this case before it is served on the person to +whom it is directed. Fed. R. Civ. P. 45(a)(4). + + +Case 1:22-cv-10904-JSR Document 37-2FilEde0102570B23P agægb02oф119 +AO 88A (Rev. 12/20) Subpoena to Testify at a Deposition in a Civil Action (Page 2) +Civil Action No. 1:22-cv-10904-JSR +PROOF OF SERVICE +(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) +I received this subpoena for (name of individual and title, if any) +On (date) +• I served the subpoena by delivering a copy to the named individual as follows: +on (date) +; or +• I returned the subpoena unexecuted because: +Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also +tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of +$ +My fees are $ +for travel and $ +for services, for a total of $ +0.00 +I declare under penalty of perjury that this information is true. +Date: +Server's signature +Printed name and title +Server's address +Additional information regarding attempted service, etc.: + + +Case 1:22-c-10904-JSR Document 32-2Filede0102522823P agage 13001199 +AO 88A (Rev. 12/20) Subpoena to Testify at a Deposition in a Civil Action (Page 3) +(c) Place of Compliance. +(1) For a Trial, Hearing, or Deposition. A subpoena may command a +person to attend a trial, hearing, or deposition only as follows: +(A) within 100 miles of where the person resides, is employed, or +regularly transacts business in person; or +(B) within the state where the person resides, is employed, or regularly +transacts business in person, if the person +(i) is a party or a party's officer; or +(li) is commanded to attend a trial and would not incur substantial +Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13) +(i) disclosing a trade secret or other confidential research, development, +or commercial information; or +(il) disclosing an unretained expert's opinion or information that does +not describe specific occurrences in dispute and results from the expert's +study that was not requested by a party. +(C) Specifying Conditions as an Alternative. In the circumstances +described in Rule 45(d)(3)(B), the court may, instead of quashing or +modifying a subpoena, order appearance or production under specified +(2) For Other Discovery. A subpoena may command: +(A) production of documents, electronically stored information, or +tangible things at a place within 100 miles of where the person resides, is +employed, or regularly transacts business in person; and +(B) inspection of premises at the premises to be inspected. +(d) Protecting a Person Subject to a Subpoena; Enforcement. +(1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney +responsible for issuing and serving a subpoena must take reasonable steps +to avoid imposing undue burden or expense on a person subject to the +subpoena. The court for the district where compliance is required must +enforce this duty and impose an appropriate sanction —which may include +lost earnings and reasonable attorney's foes—on a party or attorney who +fails to comply. +(2) Command to Produce Materials or Permit Inspection. +(A) Appearance Not Required. A person commanded to produce +documents, electronically stored information, or tangible things, or to +permit the inspection of premises, need not appear in person at the place of +production or inspection unless also commanded to appear for a deposition, +hearing, or trial. +(B) Objections. A person commanded to produce documents or tangible +things or to permit inspection may serve on the party or attorney designated +in the subpoena a written objection to inspecting, copying, testing, or +sampling any or all of the materials or to inspecting the premises—or to +producing electronically stored information in the form or forms requested. +The objection must be served before the earlier of the time specified for +compliance or 14 days after the subpoena is served. If an objection is made, +the following rules apply: +(i) At any time, on notice to the commanded person, the serving party +may move the court for the district where compliance is required for an +order compelling production or inspection. +(il) These acts may be required only as directed in the order, and the +order must protect a person who is neither a party nor a party's officer from +significant expense resulting from compliance. +(3) Quashing or Modifying a Subpoena. +(A) When Required. On timely motion, the court for the district where +compliance is required must quash or modify a subpoena that: +(i) fails to allow a reasonable time to comply; +(i) requires a person to comply beyond the geographical limits +specified in Rule 45(c); +(iil) requires disclosure of privileged or other protected matter, if no +exception or waiver applies; or +(iv) subjects a person to undue burden. +(B) When Permitted. To protect a person subject to or affected by a +subpoena, the court for the district where compliance is required may, on +motion, quash or modify the subpoena if it requires: | +(i) shows a substantial need for the testimony or material that cannot be +otherwise met without undue hardship; and +(li) ensures that the subpoenaed person will be reasonably compensated. +(e) Duties in Responding to a Subpoena. +(1) Producing Documents or Electronically Stored Information. These +procedures apply to producing documents or electronically stored +information: +(A) Documents. A person responding to a subpoena to produce documents +must produce them as they are kept in the ordinary course of business or +must organize and label them to correspond to the categories in the demand. +(B) Forms for Producing Electronically Stored Information Not Specified. +If a subpoena does not specify a form for producing electronically stored +information, the person responding must produce it in a form or forms in +which it is ordinarily maintained or in a reasonably usable form or forms. +(C) Electronically Stored Information Produced in Only One Form. The +person responding need not produce the same electronically stored +information in more than one form. +(D) Inaccessible Electronically Stored Information. The person +responding need not provide discovery of electronically stored information +from sources that the person identities as not reasonably accessible because +of undue burden or cost. On motion to compel discovery or for a protective +order, the person responding must show that the information is not +reasonably accessible because of undue burden or cost. If that showing is +made, the court may nonetheless order discovery from such sources if the +requesting party shows good cause, considering the limitations of Rule +26(b)(2)(C). The court may specify conditions for the discovery. +(2) Claiming Privilege or Protection. +(A) Information Withheld. A person withholding subpoenaed information +under a claim that it is privileged or subject to protection as trial-preparation +material must: +(i) expressly make the claim; and +(il) describe the nature of the withheld documents, communications, or +tangible things in a manner that, without revealing information itself +privileged or protected, will enable the parties to assess the claim. +(B) Information Produced, If information produced in response to a +subpoena is subject to a claim of privilege or of protection as +trial-preparation material, the person making the claim may notify any party +that received the information of the claim and the basis for it. After being +notified, a party must promptly return, sequester, or destroy the specified +information and any copies it has; must not use or disclose the information +until the claim is resolved; must take reasonable steps to retrieve the +information if the party disclosed it before being notified; and may promptly +present the information under seal to the court for the district where +compliance is required for a determination of the claim. The person who +produced the information must preserve the information until the claim is +resolved. +The court for the district where compliance is required—and also, after a +motion is transferred, the issuing court—may hold in contempt a person +who, having been served, fails without adequate excuse to obey the +subpoena or an order related to it. +For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013). + + +Case 1:22-ox10904 JSR Døcument 32-2FilEde@100522B23P agægt24oф119 +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +THIS EXHIBIT MAY INCLUDE THE NAMES OF INDIVIDUALS WHO +ARE VICTIMS OF HUMAN TRAFFICKING OR SEXUAL ABUSE, AND +THEREFORE SHOULD BE TREATED AS CONFIDENTIAL +AND NOT PUBLICLY DISCLOSED. + +I. +Definitions +Unless otherwise specified, the documents specified below are required to be produced for the +time period commencing January 1, 1998 and continuing through the present. Where +production of account data is provided in electronic format or media the preferred software +format to incorporate the data into is Microsoft Excel. +As used herein, the following terms are defined as indicated: +1. "All/Each." The term "all" and "each" shall be construed as all and each. +2. "And/Or." The connectives "and" and "or" shall be construed either disjunctively or +conjunctively as necessary to bring within the scope of the discovery request all +responses that might otherwise be construed to be outside of its scope. +3. "Communication" means the transmittal of information (in the form of facts, ideas, +inquiries or otherwise). +4. The terms "Document" or "Documents" are defined to be synonymous and equal in +scope to the usage of these terms in Federal Rule of Civil Procedure 34(a), including, +without limitation, any written, drawn, printed, typed, photographed or other graphic or +electronically or computerized recorded data or compilations of any kind or nature +prepared or received by, or in the possession, custody or control of the answering party, +its agents, servants, employees or other representatives. Originals, drafts and all nonidentical copies are separate documents within the meaning of this term. +5. "Referring to", "relating to", "reflecting", "regarding" or "with respect to" mean, without +limitation the concepts: pertain to, deal with, concern, reflect, record, report, constitute, +contain, mention, describe, discuss, analyze, evaluate, estimate, study, survey, project, + + +Case 1:22-cv-10904-JSR Document 37-2Filede@10252D823P agøgt3500f19 +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +assess, support, modify, contradict, criticize, summarize, comment, or otherwise involve, +in whole or in part. +6. "You" and "Your" shall mean Cathy Alexander. These terms also shall be deemed to +include all agents and other persons acting or authorized to act on her behalf. +Il. +Instructions +1. When providing Your responses, indicate the Request to which each Document or answer +responds in the metadata field, RequestNo. +2. Documents produced pursuant to these Requests shall be produced as they are kept in the +ordinary course of business. +3. For each Document that You produce, produce the current version together with all earlier +editions or predecessor Documents during the relevant time period, even though the title +of earlier Documents may differ from current versions. Format for Documents produced +electronically: +a. +C. +d. +Data shall be produced in single page TIFFs at a 300 DPI resolution which +are named for the +Number of the page. There shall be no more than +1000 images per folder. +numbers, confidentiality designations, and +redactions shall be burned into the TIFF image file so as not to unreasonably +obstruct any information on the page. +Document Unitization. Each page of a Document shall be electronically +converted into an image as described above. If a Document is more than +one page, the unitization of the Document and any attachments and/or +affixed notes shall be maintained as it existed in the original when creating +the image file and appropriately designated in the load files. The +corresponding parent/attachment relationships, to the extent possible, shall +be provided in the load files furnished with each production. +Include Document level text files containing optical character recognition +("OCR") or extracted text named with the +Number of the first page +of the Document. +Include data load files containing all of the metadata +(both system and +2 + + +Case 1:22-cv-10904-JSR Document 32-2FilEde@1025PPB23P ag#gb46o0f19 +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +C. +f. +h. +i. +j. +k. +application - see list below) from the original Native Documents with +extension. dat for Concordance. +Include the database field name in the first line of the metadata file, in such +a manner that it is clear how the metadata is organized in the file. +Include an image loadfile for Concordance - such as opt. +All hidden text (e.g., track changes, hidden columns, comments, notes, etc.) +shall be expanded, extracted, and rendered in the. TIFF file. +Documents created in Excel (spreadsheets), . CSV files, Access (databases), +and audio and video media files shall be produced in Native format. The +extractable metadata and text shall be produced in the same manner as other +Documents that originated in electronic form (as described herein) to the +extent that metadata exists or is reasonably accessible. +Email attachments and embedded files or links shall be mapped to their +parent. +Produce all attachments to responsive Documents attached to the responsive +Documents. +De-duplicate prior to production. To the extent that exact duplicate +Documents (based on MD5 or SHA-1 hash values at the Document level) +reside within a party's data set, each party is only required to produce a +single copy of a responsive Document, so long as there is a data field that +identifies each custodian who had a copy. In addition, Documents may be +de-duplicated in such a way as to eliminate earlier or incomplete chains of +emails, and produce only the most complete iteration of an email chain so +long as there is a data field that identifies each custodian who had a copy. +REQUIRED METADATA +BEGDOC +BEGATTACH +ATTCOUNT +CUSTODIAN +FROM +ENDDOC +ENDATTACH +ATTACH +AUTHOR +TO +3 + + +Case 1:22 cx-10904-JSR Document 32-2FilEde@100522823P agægle57o6f19 +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +CC +FILESIZE +DATERECD +DATESENT +CRTDATE +LASTMODDATE +LASTACCDATE +TITLE +EMAILSUBJECT +FILEEXT +ORGANIZATION +RECORD_TYPE +VOLUME +PRINTEDDATE +ATTLST +PSTINSIDEPATH +REQATTANDEES +REPLYTIME +BCC +PGCOUNT +TIMERECD +TIMESENT +CRTTIME +LASTMODTIME +LASTACCTIME +SUBJECT +FILENAME +MDSHASH +FULLPATH +VERSION +COMMENT +ENTRYID +ITEMTYPE +ITEMCREATIONTIME +REMINDERTIME +APPOINTMENTSTARTDATE +APPOINTMENTDURATIONTIME +APPOINTMENTCONTACT +CATEGORY +KEYWORDS +MANAGER +ENCRYPTED +LASTAUTHOR +FAMILYDATE +4 + + +Case 1: 22-ox-10904 JSR Document 37-2ilEded 0522823P agag686119 +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +NATIVELINK +TEXTPATH +REQUESTNO +4. Format for hard copies of Documents produced in response to this Request: +a. +Re-type the question or request to which the Documents respond and firmly +attach the Documents to the re-typed request; +b. +Number all Documents consecutively, consistently with the numbers used +for the Documents produced electronically. +5. Unless otherwise indicated, the relevant time period for this Request for Production of +Documents is January 1, 1998 to the present. +6. If no Documents responsive to a particular request exist, so state. +7. As to any Document which no longer exists but which You are aware existed at one time, +identify such Document with as much particularity as possible, and in addition, identify +the last known location of the Document, the reason the Document is no longer in +existence, and the person responsible for the Document's disposition. +8. For information that You withhold on the basis of privilege, provide a descriptive list of +each Document stating the grounds for Your refusal and providing the following +information: the name or title of the Document; a description of the nature and subject +matter of the Document sufficient to enable a meaningful challenge to the assertion of +privilege; the date, author(s), sender(s), and recipient(s) of the Document; and the nature +of the privilege. +9. These requests shall be deemed continuing in character so as to require prompt +supplemental responses if additional Documents called for herein are obtained, discovered, +or become known to You between the time of responding to the Requests and the final +disposition of this action. +5 + + +Case 1:22-0-10904 JSR Document 32-2ilede@102528623P agag7906119 +United States District Court for the Southern District of New York +Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. +Civil Action No. 1:22-cv-10904-JSR +10. Social Security numbers may be redacted from documents to the extent required by +applicable law. +IL. +Requests for the Production of Documents +1. +All Documents, Communications, and agreements related to Your employment by Jeffrey +Epstein, including but not limited to: +a. +Employment and agreements, +b. Non-disclosure agreements, +C. +All payments, in any form, received from or on behalf of Jeffrey Epstein, +d. +All Communications with Jeffrey Epstein, Ghislaine Maxwell, Bella Klein, Daphne +Wallace, Harry Beller, Lesley Groff, +a/k/a +Erika Kellerhals, Richard D. Kahn, and/or Darren K. Indyke. + + +Ease 1:22-€v-10904-JSR Doeument 37-3Fi|s#e@10272@ß23P#у₽g₴8106f12 +SOUTHERN DISTRICT OF NEW YORK +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS +PLAINTIFF, +Case Number: 1:22-cv-10904-JSR +V. +JPMORGAN CHASE BANK, N.A. +DEFENDANT. +[PROPOSED| ORDER FOR MOTION FOR ISSUANCE OF +'LETTER OF REQUEST (LETTER ROGATORY) +Upon consideration of the Motion for Issuance of Letter of Request (Letter Rogatory) dated +January 20, 2023, the exhibits annexed thereto, and any oppositions or replies filed with respect to +the motion, and it appearing that the testimony of and documents in the possession of Cathy +Alexander, a resident of South Africa, is material and necessary to the issues of this action, the +Court hereby GRANTS the Motion and ORDERS as follows: +1. The Court will sign and shall issue the Letter of Request (Letter Rogatory) attached as +Exhibit 1 to the Motion to facilitate the taking of the deposition upon oral examination +of Cathy Alexander as a witness in this action, as well as the production of documents +described in the Plaintiff's Motion and exhibits annexed thereto; +2. The Clerk of Court is hereby directed to take all necessary steps to ensure the Letter of +Request (Letter Rogatory) is transmitted to Plaintiff in a form sufficient to obtain the +described testimony and documents; and +1 + + +3. The appropriate judicial authority in South Africa is hereby authorized to take and +report the deposition of Cathy Alexander and shall have the power by virtue of the +Letter of Request (Letter Rogatory) to administer any necessary oath and to take and +report testimony. +SO ORDERED. +Dated: (/23/23 +New York, New York +he-lonorable . +Rakoff +Senior Judge +The United States District Court +for the Southern District of New +York +2 \ No newline at end of file diff --git a/vision-fixhub/court-05/c995354ef43e8deeaecaa2dfafae04a28c779d645b550f2d609ae43b04b388d7.receipt.json b/vision-fixhub/court-05/c995354ef43e8deeaecaa2dfafae04a28c779d645b550f2d609ae43b04b388d7.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..7b649a38d0751bc1ec09fae18641e5453bbdf9a3 --- /dev/null +++ b/vision-fixhub/court-05/c995354ef43e8deeaecaa2dfafae04a28c779d645b550f2d609ae43b04b388d7.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -684, + "dataset": "marble-joined", + "doc_id": "c995354ef43e8deeaecaa2dfafae04a28c779d645b550f2d609ae43b04b388d7", + "engine": "marble-apple-vision", + "event_count": 23, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]", + "idempotent": false, + "input_sha256": "d6be8d067ae0978b0bdca8355f9a5f9333799652b3dbb7e623f6c0ee43c4f44e", + "output_sha256": "af53119e6c43e7ce0bdeb1bff7494fc0f8314646462e8b823ec7b7cbf69fe50c", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c9982d97156b7d7e32f36de1ee70eae4a9d12c35616d5a013d9ab211cb7cf6b3.md b/vision-fixhub/court-05/c9982d97156b7d7e32f36de1ee70eae4a9d12c35616d5a013d9ab211cb7cf6b3.md new file mode 100644 index 0000000000000000000000000000000000000000..a79cf3824c13efa4f10f0aa8b98aee512b8ccc19 --- /dev/null +++ b/vision-fixhub/court-05/c9982d97156b7d7e32f36de1ee70eae4a9d12c35616d5a013d9ab211cb7cf6b3.md @@ -0,0 +1,194 @@ +Case 1:22-cV-10904-JSR Document 263-20 Filed 08/07/23 Page 1 of 8 + + + +Case 1:22-cV-10904-JSR Document 263-20 Filed 08/07/23 Page 2 of 8 +UNITED STATES DISTRICT COURT FOR THE +SOUTHERN DISTRICT OF NEW YORK +JANE DOE, individually and on behalf of +all others similarly situated, +Plaintiff, +V. +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +GOVERNMENT OF THE UNITED +STATES VIRGIN ISLANDS. +v. +Plaintiff, +JPMORGAN CHASE BANK, N.A. +Defendant/Third-Party Plaintiff. +JPMORGAN CHASE BANK, N.A. +Third-Party Plaintiff, +Case Number: 1:22-cv-10019-JSR +Case Number: 1:22-cv-10904-JSR +v. +JAMES EDWARD STALEY +Third-Party Defendant. +THIRD-PARTY DEFENDANT JAMES E. STALEY'S RESPONSES +AND OBJECTIONS TO UNITED STATES VIRGIN ISLANDS' FIRST +SET OF REQUESTS FOR ADMISSIONS +Pursuant to Rules 26 and 36 of the Federal Rules of Civil Procedure, Third-Party +Defendant James E. Staley, through undersigned counsel, hereby responds and objects to the +United States Virgin Island's First Requests for Admissions in the above-captioned matters. +1 + + +Case 1:22-cv-10904-JSR Document 263-20 Filed 08/07/23 Page 3 of 8 +Staley objects to Request No. 26 to the extent it is directed at JPMC's knowledge or actions +because Staley is not a designated 30(b)(6) witness for JPMC. As such, Staley will only respond to +the extent the Request seeks information based on his personal knowledge. +Subject to and without waiving the foregoing General Objections, and reserving the right to +amend or supplement his response as further information is discovered, Staley denies this Request. +REQUEST FOR ADMISSION NO. 27: +Admit that Epstein referred +Pagano, CEO, Chairman, and President of Sentigen Bio +Services, as a client or for additional activities or funds to JPMorgan's Private Bank. +RESPONSE TO REQUEST FOR ADMISSION NO. 27: +In addition to and specifically incorporating its foregoing General Objections, Staley +objects to Request No. 27 because the terms "referred," "client," and "additional activities or +funds" are vague because they are susceptible to more than one meaning. +Staley objects to Request No. 27 because it seeks information that is not "relevant to any +party's claim or defense" and therefore not "proportional to the needs of the case." Fed. R. Civ. P. +26(b)(1). +Staley objects to Request No. 27 to the extent it is directed at JPMC's knowledge or actions +because Staley is not a designated 30(b)(6) witness for JPMC. As such, Staley will only respond to +the extent the Request seeks information based on his personal knowledge. +Subject to and without waiving the foregoing General Objections, and reserving the right to +amend or supplement his response as further information is discovered, Staley cannot truthfully +admit or deny this request because he lacks sufficient knowledge. +REQUEST FOR ADMISSION NO. 28: +Admit that Epstein referred Andrew Farkas, founder and CEO of Island Capital Group LLC, as a +client or for additional activities or funds to JPMorgan's Private Bank. +18 + + +Case 1:22-cv-10904-JSR Document 263-20 Filed 08/07/23 Page 4 of 8 +RESPONSE TO REQUEST FOR ADMISSION NO. 28: +In addition to and specifically incorporating its foregoing General Objections, Staley +objects to Request No. 28 because the terms "referred," "client," and "additional activities or +funds" are vague because they are susceptible to more than one meaning. +Staley objects to Request No. 28 because it seeks information that is not "relevant to any +party's claim or defense" and therefore not "proportional to the needs of the case." Fed. R. Civ. P. +26(b)(1). +Staley objects to Request No. 28 to the extent it is directed at JPMC's knowledge or actions +because Staley is not a designated 30(b)(6) witness for JPMC. As such, Staley will only respond to +the extent the Request seeks information based on his personal knowledge. +Subject to and without waiving the foregoing General Objections, and reserving the right to +amend or supplement his response as further information is discovered, Staley denies this Request. +REQUEST FOR ADMISSION NO. 29: +Admit that Epstein referred Larry Page, co-founder of Google, as a client or for additional activities +or funds to JPMorgan's Private Bank. +RESPONSE TO REQUEST FOR ADMISSION NO. 29: +In addition to and specifically incorporating its foregoing General Objections, Staley +objects to Request No. 29 because the terms "referred," "client," and "additional activities or +funds" are vague because they are susceptible to more than one meaning. +Staley objects to Request No. 29 because it seeks information that is not "relevant to any +party's claim or defense" and therefore not "proportional to the needs of the case." Fed. R. Civ. P. +26(b)(1). +Staley objects to Request No. 29 to the extent it is directed at JPMC's knowledge or actions +because Staley is not a designated 30(b)(6) witness for JPMC. As such, Staley will only respond to +19 + + +Case 1:22-cv-10904-JSR Document 263-20 Filed 08/07/23 Page 5 of 8 +Subject to and without waiving the foregoing General Objections, and reserving the right to +amend or supplement his response as further information is discovered, Staley denies this Request. +REQUEST FOR ADMISSION NO. 36: +Admit that Epstein referred Prince Andrew, | +funds to JPMorgan's Private Bank. +of York as a client or for additional activities or +RESPONSE TO REQUEST FOR ADMISSION NO. 36: +In addition to and specifically incorporating his foregoing General Objections, Staley +objects to Request No. 36 because the terms "referred," "client," and "additional activities or +funds" are vague because they are susceptible to more than one meaning. +Staley objects to Request No. 36 because it seeks information that is not "relevant to any +party's claim or defense" and therefore not "proportional to the needs of the case." Fed. R. Civ. P. +26(b)(1). +Staley objects to Request No. 36 to the extent it is directed at JPMC's knowledge or actions +because Staley is not a designated 30(b)(6) witness for JPMC. As such, Staley will only respond to +the extent the Request seeks information based on his personal knowledge. +Subject to and without waiving the foregoing General Objections, and reserving the right to +amend or supplement his response as further information is discovered, Staley denies this Request. +REQUEST FOR ADMISSION NO. 37. +Admit that Epstein introduced You to and/or facilitated meetings with Prince Andrew. +RESPONSE TO REQUEST FOR ADMISSION NO. 37: +In addition to and specifically incorporating his foregoing General Objections, Staley +objects to Request No. 37 because the terms "introduced," "facilitated," and "meetings" are vague +because they are susceptible to more than one meaning. +24 + + +Case 1:22-cV-10904-JSR Document 263-20 Filed 08/07/23 Page 6 of 8 +Staley objects to Request No. 47 because it seeks information that is not "relevant to any +party's claim or defense" and therefore not "proportional to the needs of the case." Fed. R. Civ. P. +26(b)(1). +Staley objects to Request No. 47 to the extent it is directed at JPMC's knowledge or actions +because Staley is not a designated 30(b)(6) witness for JPMC. As such, Staley will only respond to +the extent the Request seeks information based on his personal knowledge. +Subject to and without waiving the foregoing General Objections, and reserving the right to +amend or supplement his response as further information is discovered, Staley cannot truthfully +admit or deny this request because he lacks sufficient knowledge. +REQUEST FOR ADMISSION NO. 48: +Admit that Epstein referred Stephen Salzman, Manager of Priderock Management, LLC, as a client +or for additional activities or funds to JPMorgan's Private Bank. +RESPONSE TO REQUEST FOR ADMISSION NO. 48: +In addition to and specifically incorporating his foregoing General Objections, Staley +objects to Request No. 48 because the terms "referred," "client," and "additional activities or +funds" are vague because they are susceptible to more than one meaning. +Staley objects to Request No. 48 because it seeks information that is not "relevant to any +party's claim or defense" and therefore not "proportional to the needs of the case." Fed. R. Civ. P. +26(b)(1). +Staley objects to Request No. 48 to the extent it is directed at JPMC's knowledge or actions +because Staley is not a designated 30(b)(6) witness for JPMC. As such, Staley will only respond to +the extent the Request seeks information based on his personal knowledge. +Subject to and without waiving the foregoing General Objections, and reserving the right to +amend or supplement his response as further information is discovered, Staley cannot truthfully +31 + + +Case 1:22-cV-10904-JSR Document 263-20 Filed 08/07/23 Page 7 of 8 +admit or deny this request because he lacks sufficient knowledge. +REQUEST FOR ADMISSION NO. 49: +Admit that Epstein referred | +Pritzker, chairman and CEO of the Pritzker Organization, as a +client or for additional activities or funds to JPMorgan's Private Bank. +RESPONSE TO REQUEST FOR ADMISSION NO. 49: +In addition to and specifically incorporating his foregoing General Objections, Staley +objects to Request No. 49 because the terms "referred," "client," and "additional activities or +funds" are vague because they are susceptible to more than one meaning. +Staley objects to Request No. 49 because it seeks information that is not "relevant to any +party's claim or defense" and therefore not "proportional to the needs of the case." Fed. R. Civ. P. +26(b)(1). +Staley objects to Request No. 49 to the extent it is directed at JPMC's knowledge or actions +because Staley is not a designated 30(b)(6) witness for JPMC. As such, Staley will only respond to +the extent the Request seeks information based on his personal knowledge. +Subject to and without waiving the foregoing General Objections, and reserving the right to +amend or supplement his response as further information is discovered, Staley admits this Request. +REQUEST FOR ADMISSION NO. 50: +Admit that You worked with Epstein to develop a donor advised fund with Bill Gates and The Bill +and Melinda Gates Foundation. +RESPONSE TO REQUEST FOR ADMISSION NO. 50: +In addition to and specifically incorporating his foregoing General Objections, Staley +objects to Request No. 50 because the terms "worked with," "develop," and "donor advised fund" +are vague because they are susceptible to more than one meaning. +Staley objects to Request No. 50 because it seeks information that is not "relevant to any +32 + + +Case 1:22-cV-10904-JSR Document 263-20 Filed 08/07/23 Page 8 of 8 +May 22, 2023 +By: /s/ Brendan V. +1. Jr. +Brendan V. +Jr. +Zachary K. +Stephen L. Wohlgemuth +& CONNOLLY LLP +680 Maine Avenue SW +Washington, DC 20024 +Tel: (202) 434-5252 +Fax: (202) 434-5029 +zwarren@wc.com +Counsel for Third-Party Defendant +James Edward Staley +5 diff --git a/vision-fixhub/court-05/c9982d97156b7d7e32f36de1ee70eae4a9d12c35616d5a013d9ab211cb7cf6b3.receipt.json b/vision-fixhub/court-05/c9982d97156b7d7e32f36de1ee70eae4a9d12c35616d5a013d9ab211cb7cf6b3.receipt.json new file mode 100644 index 0000000000000000000000000000000000000000..e5878068192e5eedc80cf4a7fdb539937194327e --- /dev/null +++ b/vision-fixhub/court-05/c9982d97156b7d7e32f36de1ee70eae4a9d12c35616d5a013d9ab211cb7cf6b3.receipt.json @@ -0,0 +1,14 @@ +{ + "byte_delta": -106, + "dataset": "marble-joined", + "doc_id": "c9982d97156b7d7e32f36de1ee70eae4a9d12c35616d5a013d9ab211cb7cf6b3", + "engine": "marble-apple-vision", + "event_count": 9, + "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]", + "idempotent": true, + "input_sha256": "b6249b784aa5292055667c300b32ada33ec12fda8cf518ca5eecb84876fec255", + "output_sha256": "e8c6b61da3c70432f5e982efda4a6cea9ef9a75cd298a1269c706a78c695dade", + "page_markers": false, + "source_id": "epstein-external", + "text_format": "markdown" +} diff --git a/vision-fixhub/court-05/c9a44ea60cc69b48470f97ff9ba5a0e11213bd4b1be7cc58a1f110830fde043d.md b/vision-fixhub/court-05/c9a44ea60cc69b48470f97ff9ba5a0e11213bd4b1be7cc58a1f110830fde043d.md new file mode 100644 index 0000000000000000000000000000000000000000..d1552c6b96e37973899e0aa14418d0fd99a84244 --- /dev/null +++ b/vision-fixhub/court-05/c9a44ea60cc69b48470f97ff9ba5a0e11213bd4b1be7cc58a1f110830fde043d.md @@ -0,0 +1,76 @@ +Case 1:22-cv-10904-JSR Document 284-57 Filed 08/14/23 + + +FILED UNDER SEAL + + +Case 1:22-cV-10904-JSR Document 284-57 Filed 08/14/23 Page 2 of 3 +Date: 2/13/2014 10:33:13 PM +From: "Cecile de Jongh" +To : "Mukamal, +Ce : "jeanne", "Simonton, Eric", "Lande, Mark" +Subject : Re: AYH P dock +Ok, great. I think he can be very helptill. +With warmregards, +Cecile +Sent from my iPhone and misspellings courtesy of iPhone. +On Feb 13, 2014, at 6:30 PM, 'Mukamal, +wrote: +Thank you Cecile - +I had already discussed the matter with Celestino and asked for his advice as it was developing - I will see if he is available. +Best, +Tom +From Cecile de Jongh +Sent: Thursdav February 15, 2014 5227 PM +To: Mukamal, +Cc: jeanne; Simonton, Eric; Lande, Mark +Subject: Re: AYH P dock +Good evening Tom. +I have been giving this subject some thought and I think you should consider having Celestino +not think the members of the CZM Commission will go against Celestino. Just a thought. +go with you and Jamie to the hearing. I do +With warm regards, +Cecile +Sent from my iPhone and misspellings courtesy of iPhone. +On Feb 12, 2014, a: 10:24 AM, "Mukamal, | +wrote: +Cecile & Jeanne - +These are draft exhibits we intend to use in presenting our objection to CZM. While they may change a bit, I think it will be helpful if we can +walk you through these today as it will help in understanding what is going on. +Thanks, +Tom +Tom Mukamal +President +Island Global Yachting Ltd. +717 Fifth Avenue, 18th Floor +New York, New York 10022 +This message, and any attachments hereto, is confidential and intended exclusively for the use of the individual or entity to whom it is +addressed. This communication may contain information that is confidential, proprietary, privileged, subject to a confidentiality and/or nondisclosure agreement, or otherwise exempt or protected from disclosure (either by contract or under applicable law). If you are not the +intended recipient, vou are hereby notified that printing. retaining, reproducing, copying, disclosing. disseminating or using this message or +any information contained herein (including any reliance thereon) is strictly prohibited. If you have received this message in error, please +contact the sender immediately and destroy the message (including any attachments) and any copies in their entirety, whether in electronic or +hard copy format. Nothing contained in this e-mail shall be considered a legally binding agreement, amendment or modification of any +agreement with Island Capital Group LLC or any of its affiliates, each of which requires a fully executed agreement to be received by Island +Capital Group LLC or such affiliate. + +ESTATE_JPM059347 + + +Case 1:22-cV-10904-JSR Document 284-57 Filed 08/14/23 Page 3 of 3 +Thismessage, and any attachments hereto, is confidential and intended exclusively for the use of the individual or entity to whom it is addressed. This communication may contain +information that is confidential, proprietary, privileged, subject to a confidentiality andior non-disclosure agreement, or otherwise exempt or protected from disclosure (either by contract or +under applicable law). If you are not the intended recipient, you are hereby notified that printing, retaining, reproducing, copying, disclosing, disseminating or using thismessage or any +information contained herein (including any rellance thereon) is strictly prohibited. If you have received this message in enor, please contact the sender immediately and destroy the +message including any attachments) and any copies in their entirety, whether in electronic or hard copy format, Nothing contained in thise-mail shall be considered a legally binding +greement, amendment or modification of any agreement with Island Global Yachting LTD or any of its affiliates, each of which requires a fully executed agreement to be received by +dand Global Yachting LTD or such affiliate +