EXHIBIT 2¶
UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK¶
GOVERNMENT OF THE UNITED ) STATES VIRGIN ISLANDS ) )¶
Plaintiff, )¶
V. ) Case Number: 1:22-cv-10904-JSR¶
JPMORGAN CHASE BANK, N.A. )¶
Defendant/Third-Party Plaintiff. )¶
) )¶
JPMORGAN CHASE BANK, N.A. )¶
Third-Party Plaintiff, )¶
V. )¶
JAMES EDWARD STALEY )¶
Third-Party Defendant. )¶
DECLARATION OF LINDA , ESQ. IN SUPPORT OF GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS’ MOTION FOR ORDER AUTHORIZING ALTERNATIVE SERVICE OF SUBPOENA FOR THIRD PARTY ELON MUSK¶
I, Linda =, declare in support of Plaintiff, the Government of the United States Virgin Islands’ (“the Government”), Motion for Order Authorizing Alternative Service of Subpoena for Third Party Elon Musk as follows:¶
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- I am an attorney with Motley Rice LLC, counsel for the Government, and am admitted to practice in the above-captioned matter.
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- Motley Rice hired the investigative firm Gryphon Strategies to search public records databases for an address for Elon Musk.
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Gryphon Strategies identified contact information for Mr. Musk’s counsel who has waived service on Mr. Musk’s behalf in several recent federal cases filed within the last year, as well as the business address for Tesla, Inc., which was the service address listed for Mr. Musk on summonses issued in recent federal litigation.
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I emailed Mr. Musk’s counsel to notify him of the Government’s subpoena and ask him whether he was authorized to accept service on behalf of Mr. Musk in this matter. While he did respond to my initial email, he did not respond to a subsequent email or confirm or deny his authority to accept service.
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In addition, Motley Rice’s process server attempted service at the business address for Tesla, Inc., but was unable to serve Mr. Musk at that location. See Non-Service Affidavit of Ryan Schedler attached as Exhibit A.
I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.¶
Executed this 15th day of May 2023 at Washington, D.C.¶