UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK¶
GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, Plaintiff, -against-JP CHASE BANK, N.A., Defendant. : 23-cv-10301-AS : NOTICE OF MOTION •¶
PLEASE TAKE NOTICE that, upon the accompanying Declaration of Jordan Merson and Memorandum of Law, both dated April 2024, Proposed Intervenors, by and through their undersigned counsel, shall move this Court at the Daniel Moynihan United States Courthouse, 500 Pearl Street, New York, New York 10007, for an Order granting them access to the unredacted filings in this action to the parties and their counsel in accordance with the same Protective Order entered in this action, together with such other and further relief as this Court deems just and proper.¶
Dated: April 29, 2024 New York, New York¶
Respectfully submitted,¶
MERSON LAW PLLC¶
By: /s/ Jordan Merson Jordan Merson, Esq. 950 Third Avenue, 18th Floor New York, NY 10022 Telephone: (212) 603-9100 Fax: (347)- 441-4171 JMerson@MersonLaw.Com Counsel for Proposed Intervenors¶
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK¶
x GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, Plaintiff, -against-JP CHASE BANK, N.A., Defendant. x • 23-cv-10301-AS¶
DECLARATION OF JORDAN MERSON IN SUPPORT OF PROPOSED INTERVENORS’ MOTION¶
- I. I, Jordan Merson, Esq., hereby declare as follows:
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- I am a member of the law firm Merson Law, PLLC and counsel for Proposed Intervenors in this action. Proposed Intervenors are the Plaintiffs in the action, Doe v. USVI, et at, 23-cv-10301 (AS), presently pending in this Court.
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- I make this Declaration in support of Proposed Intervenors’ motion for an Order granting them access to the unredacted filings and access to certain complete deposition transcripts related to USVI defendants in this action to the parties and their counsel in accordance with the same Protective Order entered in this action. If this application is granted, said Protective Order will be circulated to counsel for the parties in the Doe v. USVI, el at, 23-cv-10301 (AS) action.
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- In support thereof, I annex: Exhibit A - a Proposed Confidentiality Order; and Exhibit B - this Court’s Order in Doe I v. JP JSR, Document 5. Chase & Co., 22-cv-10019-
Dated: April 29, 2024 New York, New York¶
Respectfully submitted,¶
MERSON LAW, PLLC¶
By: /s/ Jordan Merson¶
Jordan Merson 950 Third Avenue, 18th floor New York, NY 10022 Telephone: (212) 603-9100 Fax: (347)- 441-4171 JMerson®MersonLaw.Com Counsel for Plaintiff¶