Draft: efta02810511

I. I am a member in good standing of the bars of the State of New York and the District of Columbia. I am one of the attorneys representing the Government of the United States Virgin Islands in the above-captioned action and have been admitted to this Court pro hac vice. I am a Member of the law firm of Motley Rice LLC, 401 9th Street NW, Suite 630, Washington, DC 20004. I am familiar with the facts set forth herein and if called as a witness, I could and would competently testify thereto. I submit this declaration and the attached Exhibits in support of the United States Virgin Islands' Motion for Partial Summary Judgment.¶

2. Attached hereto are true and correct copies of the following:¶

Exhibit Number		Description
Exhibit 1	Article by Kevin Breuninger, et al., JPMorgan Prepared to Pay $290 Million in	victim-in-lawsuit.html.
Exhibit 2	Document at	JPM-SDNYLIT-W-00018180-00018196 produced by matter and filed under seal. [Sealed]
Exhibit 3	Document at	JPM-SDNYLIT-W-00002185-00002196 produced by
	JPMorgan in this Action,	designated Confidential by JPMorgan pursuant to the
	Protective Order in this	matter and filed under seal. [Sealed]
Exhibit 4	Document at	JPM-SDNYLIT-00184442-00184461, JPM-SDNYLIT matter and filed under seal. [Sealed]
Exhibit 5	August 10, 2019, email,	JPM-SDNYLIT-00154364 produced by
Exhibit 6	Article by William K. Rashbaum,	Weiser, & Michael Gold, Jeffrey
Exhibit 7	Document, "Risk Level & Designation Determination," New York State	Division of Criminal Justice Services,
Exhibit 8	Document at [Sealed]	EVCP00000006 produced by nonparty Epstein Victims
Exhibit 9	Excerpt of Expert Report of Bridgette Carr, June 16, 2023. Designated

Exhibit	10	Document	at
				Confidential	pursuan	t to the	Protective		Order	in	this		matter	and filed
		under	seal	[Sealed]
Exhibit	11	Document	at	JDoe	DBAG_010034		-010044	pro	duced	by a		nonpar	ty in	this
		Action,	designated		Confidential	pursuan	t to	the	Protective		Order	in	this	matter
		and fi	led under	seal	[Sealed]
Exhibit	12	Document	at		JDoe_DBAG_010023		-010032	pro	duced	by	a	nonpar	ty	in this
		Action,	designated		Confidential	pursuan	t to	the	Protective			Order in	this	matter
		and fi	led under	seal	[Sealed]
Exhibit	13	Document	at		JDoe	JPMC_007438		-007448	pro	duced		by	Plaintiff	Doe in
		this	Action,	designated		Confidential	pursuan t	to	the	Protective		Order	in	this
		matter	and fi	led under	seal	[Sealed]
Exhibit	14	Document	at	=JDoe		JPMC_007449		-007464	pro	duced		by	Plaintiff	Doe in
		this	Action,	designated		Confidential	pursuan	t to	the	Protective		Order		in this
		matter	and fi	led under	seal	[Sealed]
Exhibit	15	Document	at	=LC	000456	-000476	pro	duced	by	a	nonpar	ty in	this	Action,
			designated	Confidential	pursuan	t to the		Protective		Order in	this		matter	and filed
		under	seal	[Sealed]
Exhibit	16	Creditor's		Claim on	behalf of	Jane Doe	981:	In	the	Matter	of	the	Estate	of
		Je f frey	Epstein,		Superior Court	of the	Virgin		Islands,	March		12,	2020
Exhibit	17	Creditor's		Claim on	behalf of		In		the	Matter	of	the	Estate	of Jefrey
		Epstein,	Superior		Court of the	Virgin	Islands,		November		26,	2019
Exhibit	18		Complaint,	Jane Doe	No 2 v	Epstein,	No 08	-cv	-80119	(S	.D	Fla	Feb	6,
Exhibit	19	Excerpt	of		Complainta	Epstein,	No 10	-cv	-81111	(S	.D	Fl	Sept	17,
	Exhibit 20		Complaint and	Demand	for	Jury Trial,	Jane	Doe	No	102	v	Epstein,		No 09 -cv
		80656	(S .D	Fla May	4, 2009)
	Exhibit 21	First	Amended		Complaint,	Jane Doe 43	v	Epstein,		No 17	-cv	-616	(S	.D .N .Y
		June	5, 2017)
	Exhibit 22	Flight	manifests	at		ESTATE_000454,			ESTATE		000464,
			ESTATE_000466,			ESTATE_000474,		ESTATE		000500,			ESTATE_000536
		pro	duced by	nonpar	ty The	Estate of	Jeffrey	E	Epstein	in	this		Action,	designated
			Confidential	pursuan	t to the	Protective	Order	in	this	matter		and fi	led	under seal

Exhibit 23 Flight		manifests	at		MiESTATE_000570			-000572	pro duced	by	nonpar	ty The
Estate	of	Jeffrey	E	Epstein	in this	Action,		designated		Confidential	pursuan	t to
the		Protective	Order	in this	matter	and fi	led	under seal	[Sealed]
Exhibit 24	Excerpts	of	flight	manifests	at	LV	000198,		LV_000204	-000206,		LV
	000256	-000257	pro	duced	by nonpar	ty	Larry	Visoski	in this	Action,		designated
	Confidential		pursuan	t to the	Protective		Order	in this	matter	and filed	under	seal
Exhibit 25	Flight	manifests	at	.LV		000339	-000340,	LV	000362	-00363,
	LV_000381		-000382,	L	000391	-000392,		LV_000401		-000402 pro	duced	by
	nonpar	ty Larry	Visoski	in	this	Action,	designated		Confidential	pursuan	t	to the
	Protective		Order in	this matter	and	filed	under	seal	[Sealed]
Exhibit 26	Flight	manifests	at	=LV		000423	-000424,	LV	000429	-000430,
LV		000473	-00047	‘UN	000491	-000492	pro	duced	by nonpar	ty	Lany	Visoski
in	this	Action,	designated		Confidential		pursuan	t to the		Protective	Order in	this
	matter	and fi	led under	seal	[Sealed]
Exhibit 27	Document	at		JPM	-SDNYL1T	-W	-00038289,		JPM	-SDNYLIT	-W
	00038401		-00038408	pro	duced by	JPMorgan		in this	Action,	designated
	confidential		by	JPMorgan	pursuan	t to	the	Protective	Order	in this	matter	and
fi	led	under	seal	[Sealed]
Exhibit 28	Excerpts	of	JPMorgan	Chase	Bank,	N .A	's	Responses	and	Objections	to	Third
	Party	Defendant's		(Staley)	First	Request	for	Admissions,	No	22 -cv	-10019	-JSR,
	dated	May	22, 2023
Exhibit 29	Document	at	MEJPM		-SDNYLIT		-00128026	-00128033		pro duced	by
	JPMorgan	in		Action,	and prev	iously	marked	as	Penn	Exhibit 2	at
	deposition		JPMorgan	initially		designated	this	document		Confidential		pursuan t
to	the	Protective	Order	in	this	matter but	has	withdrawn	the	designation
Exhibit 30	Document		at	JPM	-SDNYLIT		-00131915		-00131916	pro duced	by
	JPMorgan		in this	Action,	designated		Confidential	by	JPMorgan		pursuan	t to the
	Protective		Order in	this	matter	and filed	under	seal	[Sealed]
Exhibit 31	Due	Diligence	Report	approve	d	on April	14,	2011 , =		JPM	-SDNYLIT
	00036570		-00036578	pro	duced by		JPMorgan	in this	Action,	and prev	iously
	marked	as	Langford	Exhibit	53	at	deposition	JPMorgan		initially	designated	this
	document		Confidential		pursuan t	to the	Protective		Order in	this matter	but	has
	withdrawn		the	designation	in par	t and	the	document	is filed	under	seal in	par t
	[Sealed	in	par t]

Exhibit 32	Transcript	excerp	ts of the	Deposition		of	Mary S		taken	April	7, 2023 , in
this	Action		JPMorgan has	withdrawn		its	initial	designation		of	Confidential for
the	testimony		contained	in these	excerp	ts
Exhibit 33	Transcript	excerp	ts of the	30(6)(6)		Deposition	of	Senior		Advisor,	Risk and
	Compliance,		Francis	Pearn,	taken	on March	29,	2023,	in this		Action
	JPMorgan	has	withdrawn	its initial		designation	of		Confidential	for	the
	testimony	contained	in	these excerp		ts
Exhibit 34	Transcript	excerp	ts of the	Deposition		of Vice		Chairman	and		Banker, Private
	Bank,	William	Marcus	Sheridan,		taken	on July	12, 2023,		in this	Action
	Designated		Confidential	by	JPMorgan	pursuan	t to	the	Protective		Order in this
	matter and	filed	under	seal [Sealed]
Exhibit 35	Transcript	excerp	ts of	Deposition	of	Private	Bank	Risk		Manager,	Kevin
	McCleerey,	taken	on	April 28,	2023	, in this	Action		JPMorgan	has	withdrawn
its	designation		of	Confidential	for	the	testimony	contained	in	these	excerp ts
Exhibit 36	Transcript	excerp	ts of	Deposition	of	former	AML		Compliance		Manager,
	Maryanne	Ryan,	taken	May 24,		2023, in	this Action,		designated		Confidential
in	par t by	JPMorgan		pursuan t to	the	Protective	Order	in	this	matter	and filed
	under seal	in par	t [Sealed	in par	t]
Exhibit 37	Due	Diligence	Report	from Aug	-Sept	2006,		JPM		-SDNYLIT
	00037183	-00037205,	pro	duced	by	JPMorgan	m this		Action,	and	prev iously
	marked as		Exhibit	17 at		deposition	JPMorgan		initially		designated this
	document		Confidential	pursuan t	to	the	Protective	Order	in	this	matter but has
	withdrawn	the	designation	in par	t	and the	document	is fi	led	under	seal in par t
	[Sealed	in par t]
Exhibit 38	Excerpt	of Due	Diligence	Report		reques ted	February	22,	2011	,	=JPM
	SDNYLIT		-00013546,	JPM	-SDNYLIT		-00013551	, pro	duced		b7SPFlorgan in
	this Action,	and	prev	iously marked		as	Langford	Exhibit	49	at	deposition
	JPMorgan	initially		designated	this	document		Confidential		pursuan	t to the
	Protective	Order	in this	matter	but	has	withdrawn	the	designation		in par t and the
	document	is fi	led under	seal in	par t	[Sealed	in par	t]
Exhibit 39	Excerpts	of	JPMorgan	Chase	Bank,	N .A 's	Responses		and	Objections	to
	Plaintiff	Government	of	the	United	States	Virgin	Island's		First	Request for
	Admissions,	No	1:22 -cv	-10904		(JSR) (S .D	.N .Y .),	dated	May	17,	2023
	JPMorgan	initially		designated	this	document	as	Confidential		pursuan	t to the
	Protective	Order	in this	matter	but	has	withdrawn	the	designation		in par t and the
	document	is fi	led under	seal in	par t	[Sealed	in	par t]

Exhibit 40
	Article,	After	long	pro be,		billionaire	faces		solicitation	charge,		The	Palm Beach
	Post	(July	26, 2006),	prev	iously		marked	as &does		Exhibit 9	at	deposition	in this
Exhibit 41		Probable	Cause	Affidavit,	Palm		Beach	Police	Department,		dated	May	1 , 2006,
	and	prev	iously	marked as		Langford	Exhibit	15	at	deposition	in	this	Action
		JPMorgan	initially		designated	this	document		Confidential		pursuan	t to	the
		Protective	Order	in this	matter	but	has	withdrawn	the		designation	in	par t and the
		document	is filed	under	seal in	par t		[Sealed in	par t]
Exhibit 42	July	28,	2006,	article from	ABC		News:	Titter,		Warrants		Were	Prepared to
	Arrest	Others	in	Millionaire		Sex	Scandal,		JPM		-SDNYLIT		-00269657
		00269691 ,	pro duced	by	JPMorgan		in the	Action,		designated		Confidential	by
		JPMorgan	pursuan	t the	Protective		Order	in this	matter	and	filed	under	seal
Exhibit 43	August	14,	2006,	email,		JPM		-SDNYLIT		-00105859,	pro	duced	by
		JPMorgan	in this	Action,	and	a New	York	Post	article	by	Dan	Mangan,	Mystery
		Mogul's	Teen -Sex	Secret	Bared	in	Probe,	dated	August	14,	2006,
		http://www	.nypost					.com/news/regionalnews/mystertmoguls_teen					sex secret_b
	ared	in pro	be reg	ionalnews			angan	hUn,	accessed		April	4	2023,
		together	prev iously	marked		as=		Exhibit 11	at	deposition		JPMorgan
		initially	designated	this	document			Confidential	pursuan	t to	the	Protective	Order
	in	this matter	but	has	withdrawn		the	designation	in par	t and	the		document is
	filed	under	seal in	par t	[Sealed	in	par t]
Exhibit 44	AML		Operations	Human		Trafficking		Overview,		JPM		-SDNYLIT
		00174047	-00174061	,	dated	August	5,	2008, pro	duced	by	JPMorgan		in this
		Action, and	is an	excerp	t of a		document	prev	iously	marked	as	Langford	Exhibit
	14	at	deposition,	JPMorgan		initially		designated	this	document			Confidential
		pursuan t	to the	Protective		Order in	this	matter	but has		withdrawn	the
		designation	for	this por	tion of		Langford	Exhibit	14
Exhibit 45		September	22,	2006,	email	and	attachment,		JPM		-SDNYLIT		-00269393
		00269403,	pro	duced by		JPMorgan	in this	Action,		designated		Confidential	by
		JPMorgan	pursuan	t the	Protective		Order	in this	matter	and	filed	under	seal
Exhibit 46		Transcript	excerp	ts of	Deposition		of	Third	-Party	Defendant		James	E Staley,
	taken	on	June 10	-11 ,	2023 , in	this	Action,		designated		Confidential	in	par t by
		JPMorgan	pursuan	t to	the	Protective		Order in	this	matter	and fi	led	under seal in
	par	t [Sealed	in	par t]
Exhibit 47	July	26,	2006,	email,		JPM	-SDNYLIT		-00099334,		pro	duced	by JPMorgan
	in	this	Action,	and prev	iously		marked as	Erdoes		Exhibit 8	at	deposition

	JPMorgan initially designated this document Confidential pursuant to the Protective Order in this matter but has withdrawn the designation.
Exhibit 48	Excerpts of Third-Party Defendant James E. Staley's Responses and Objections to United States Virgin Islands' First Set of Request for Admissions, dated May 22, 2023.
Exhibit 49	May 21, 2003, email, [REDACTED] <b>JPM-SDNYLIT-00137281</b> , produced by JPMorgan in this Action, and an article by Vicky [REDACTED], <i>The Talented Mr. Epstein</i> , Vanity Fair (March 1, 2003), <a href="https://www.vanityfair.com/news/2003/03/jeffrey-epstein-200303">https://www.vanityfair.com/news/2003/03/jeffrey-epstein-200303</a> (accessed March 31, 2023), together previously marked as [REDACTED] Exhibit 4 at deposition. JPM-SDNYLIT-00137281 is stamped Confidential, but JPMorgan has withdrawn the designation
Exhibit 50	Document at [REDACTED] <b>JPM-SDNYLIT-W-00025790 - 00025790_003</b> , produced by JPMorgan in this Action, and previously marked as Dimon Exhibit 125 at deposition. Designated Confidential by JPMorgan pursuant the Protective Order in this matter and filed under seal. [Sealed]
Exhibit 51	Document at [REDACTED] <b>JPM-SDNYLIT-W-00025792 - 00025792_003</b> , produced by JPMorgan in this Action, and previously marked as Dimon Exhibit 126 at deposition. Designated Confidential by JPMorgan pursuant the Protective Order in this matter and filed under seal. [Sealed]
Exhibit 52	Document at <b>JPM-SDNYLIT-W-00025791 - 00025791_003</b> , produced by JPMorgan in this Action, and previously marked as Dimon Exhibit 127 at deposition. Designated Confidential by JPMorgan pursuant the Protective Order in this matter and filed under seal. [Sealed]
Exhibit 53	Presentation, "Human Trafficking," [REDACTED] <b>JPM-SDNYLIT-00151917-00151921</b> , produced by JPMorgan in this Action, and previously marked as Pearn Exhibit 8 at deposition. JPMorgan initially designated this document Confidential pursuant to the Protective Order in this matter but has withdrawn the designation.
Exhibit 54	Document at [REDACTED] <b>JPM-SDNYLIT-00174386-00174391</b> , produced by JPMorgan in this Action, designated Confidential by JPMorgan pursuant the Protective Order in this matter and filed under seal. [Sealed]
Exhibit 55	Document at [REDACTED] <b>JPM-SDNYLIT-W-00037475-00037476</b> , produced by JPMorgan in this Action, designated Confidential by JPMorgan pursuant the Protective Order in this matter and filed under seal. [Sealed]

Exhibit	56	Expert	Report		of Jorge	Amador,	June	16, 2023	Designated	Confidential
		pursuan	t	to the	Protective	Order	in this	matter	and filed	under seal
Exhibit	57	Index	of	account	statements	for	Epstein's	JPMorgan	account	ending	in	0438,
		pro duced		by JPMorgan		in this	Action	'
Exhibit	58	Index	of	account	statements	for	Epstein's	JPMorgan	account	ending	in	1001 ,
		pro	duced	by JPMorgan		in this	Action	'
Exhibit	59	Index	of	account	statements	for	Financial	Trust's	JPMorgan	account	ending	in
		0001	, pro	duced	by JPMorgan	in	this	Action '
Exhibit	60	Index	of	account	statements	for	Financial	Trust's	JPMorgan	account	ending	in
		5001	, pro	duced	by JPMorgan	in	this	Action .'
Exhibit	61	February		8, 2006,	email,		JPM -SDNYLIT		-00449033	, pro	duced	by
		JPMorgan		in	this action,	designated	Confidential		by JPMorgan	pursuan		t to the
		Protective		Order	in this	matter	and filed	under	seal [Sealed]
Exhibit	62	Excerpts		of JPMorgan		Chase Bank,	N	.A 's Responses	and	Objections		to
		Plaintiff		Doe's	First Request	for	Admissions,		Case No	1:22 -cv	-10019,	dated
		March	23	, 2023
Exhibit	63	Oct	19	-23, 2007,	email	thread	with multiple		attachments,		JPM
		SDNYLIT		-00269651	-00269660,		pro	duced by	JPMorgan	in this	Action,	and
		prev	iously	marked	as Cutler	Exhibit		8 at deposition	JPMorgan		initially
		designated		this	document	Confidential		pursuan	t to the	Protective	Order	in this
		matter	but	has	withdrawn	the	designation	in par	t and the	document	is	filed under
		seal	in	par t	[Sealed in	par t]
Exhibit	64	Account		summary	for	account	*e nding	in 2810,	JPM	-SDNYLIT
		00091213,		pro	duced by	JPMorgan	in	this Action,	designated	Confidential		by
		JPMorgan		pursuan	t to	the Protective		Order in	this matter	and fi	led under	seal
Exhibit	65	Document		at	JPM	-SDNYLIT		-00104316	-00104317,	pro	duced	by
		JPMorgan		in	this Action,	designated		Confidential	by JPMorgan		pursuan	t to the
		Protective		Order	in this	matter	and filed	under	seal [Sealed]

Tor all account statements, the Government is producing an index rather than attaching these documents because they are voluminous (thousands of pages). The Government's SUF includes tables summarizing relevant information from the account statements. The Government will provide these documents to the Court at its request.¶

Exhibit 66 January	14,	2011	, email	and	attachment,			JPM		-SDNYLIT		-00152804
00152806,	pro		duced	by	JPMorgan,	and	prev	iously	marked	as	Ryan	Exhibit 34
at	deposition		WMorgan		initially	designated		this	document		Confidential
pursuan	t to	the	Protective		Order in	this	matter	but	has	withdrawn	the
Exhibit 67 Document	at			JPM	-SDNYLIT		-00149696		-00149700,	pro	duced	by
JPMorgan	in	this	Action,		designated		Confidential		by	IPMorgan	pursuan	t to the
Protective		Order	in this	matter	and	filed	under	seal	[Sealed)
Exhibit 68 February	9,	2004,	Due		Diligence	Report,		MilJPM		-SDNYLIT		-00036564
00036569,		pro	duced	by	JPMorgan	in this	Action,		and	prev iously		marked as
Erdoes	Exhibit	6	at	deposition		JPMorgan		initially		designated	this	document
	Confidential		pursuan t	to the	Protective		Order	in this	matter	but	has	withdrawn
the	designation		in par	t and	the	document	is fi	led	under	seal in	par t	[Sealed in
par t]
Exhibit 69	Document	at		SDNYLIT	-W	-00041545		-00041550,		pro	duced	by JPMorgan
in this	Action,		designated		Confidential		by	JPMorgan		pursuan t	to the	Protective
Order	in this		matter	and fi	led under	seal	[Sealed]
Exhibit 70 January	10,	2011	, email,		JPM		-SDNYLIT		-0015274811		, pro	duced by
	JPMorgan	in this	Action,		and prev	iously	marked	as	Cutler		Exhibit 28	at
	deposition		JPMorgan	initially		designated	this		document		Confidential	pursuan t
to the	Protective		Order	in	this matter	but	has	withdrawn		the	designation
Exhibit 71	Document	entitled,		"Human		Trafficking	Finance:		Nature,	Scope	and	Control
Project,"		November		2010		JPM	-SDNYLIT		-00173973		-00173992,
pro	duced by		JPMorgan	in		Action,	and prev		iously	marked	as	Th ellibit
38 at	deposition			JPMorgan	initially		designated	this		document		Confidential
pursuan	t to	the	Protective		Order	in this	matter	but	has	withdrawn	the
	designation	in	par t	and the	document	is	filed	under	seal	in par	t	[Sealed in
par t]
Exhibit 72 John	Carney,		Meet				Star	Girl	of the	Raunchiest		Part of
Epstein		Scandal,		Dealbreaker	(July	28,	2006),
	https://dealbreaker					.com/2006/07/meet		-M=M		-star-girl		-of-the
		raunchiest-part-of-epstein			-scandal,		accessed	July 1	, 2023
Exhibit 73 March	8,	2007,	email	and	attachment,			JPM		-SDNYLIT	-00001494
	00001496,	pro	duced	by	JPMorgan	in	this	Action	and	prev	iously	marked as
	Exhibit		15	JPMorgan		initially	designated		this	document		Confidential
	pursuant to	the		Protective	Order	in this	matter	but	has	withdrawn	the
	designation	in	par t	and the	document	is	filed	under	seal	in par	t	[Sealed in
par	t]

Exhibit 74	June 9,	2010,	email,	MIJPM		-SDNYLIT		-00008237		-00008240,	pro	duced by
	JPMorgan		in this	action,	and	prev iously	marked	as		illExhibit	35	at
	deposition		JPMorgan		initially	designated	this		document		onfidential	pursuan t
to	the	Protective		Order in	this	matter	but has	withdrawn		the	designation	while
	retaining	its	original		redactions	to the	document
Exhibit 75	Document		at	JPM	-SDNYLIT		-00026318,	pro	duced	by	JPMorgan	in this
	Action,		designated		Confidential	by	JPMorgan	pursuan	t	to the	Protective	Order
in	this	matter	and fi	led	under	seal	[Sealed]
Exhibit 76 Oct		17, 2006	Rapid		Response	Team	memorandum,			IIIIJPM	-SDNYLIT
	00127953,		pro duced	by	JPMorgan	in	this	Action,	an prev	iously		marked as
	Erdoes	Exhibit	3 at		deposition	JPMorgan		initially	designated		this	document
		Confidential	pursuan	t to	the	Protective	Order	in this	matter	but	has	withdrawn
	the	designation
Exhibit 77	Transcript		excerp ts	of the		Deposition	of Risk		Manager,		Bonnie!	" taken
	May	10,	2023, in	this	Action,	designated		Confidential	in	par t by		organ
	pursuan	t to	the	Protective	Order	in this	matter	and	filed	under	seal in	par t
	[Sealed	in	par t]
Exhibit 78		Document	at a					RM-SDNYLIT-W-00021995			pro	-00021996, duced by
		JPMorgan	in 's	Action,	and	prev iously		marked as		DeLuca	Exhibit	29 at
	deposition		Designated		Confidential		pursuan	t to the		Protective	Order	in this
	matter	and	filed	under	seal	[Sealed]
Exhibit 79	Currency		Transaction		Reports,	pro	duced by	third	-arty	the	Financial	Crimes
		Enforcement	Network		("FinCEN1	in	this	Action
Exhibit 80	July	16,	2008, email	and		attachment,	= .7IPM		-SDNYLIT		-00269718
		00269719,	pro duced	by	JPMorgan	in	Miaction,		designated		Confidential
	pursuan	t to	the	Protective	Order	in this	matter	and	filed	under	seal	[Sealed]
Exhibit 81		Document	at = .IPM		-SDNYLIT	-W	-00021932			-00021937,	pro	duced by
		JPMorgan	in Ni	Action,	and	prev	iously	marked	as	McCleerey	Exhibit	13 at
		deposition	Designated		Confidential		pursuan	t to	the	Protective	Order	in this
	matter	and	filed	under	seal	[Sealed]
Exhibit 82		Document	at =	JPM		-SDNYLIT	-W	-00021965		-0021966,	pro	duced by
		JPMorgan	in Os	iction,	and	prev	iously	marked	as Ryan	Exhibit	23	at
		Deposition	JPMorgan		initially	designated		this	document		Confidential	pursuan t

"The Government is producing an index rather than attaching the currency transaction reports because they are voluminous (nearly 700 pages). The Government's SUF includes tables summarizing relevant information from the currency transaction reports. The Government will provide these documents to the Court at its request.¶

to	the	Protective		Order	in this	matter	but	has	withdrawn	the	designation	in par t
and	the		document	is	filed	under	seal in	par t	[Sealed	in par	t]
Exhibit 83 July	19,	2013,		email,		JPM	-SDNYLIT		-00100966,	pro	duced	by JPMorgan
in	this	Action,	and	prev	iously		marked as	Erdoes		Exhibit 30	at	deposition
	JPMorgan		initially		designated	this		document	Confidential		pursuan	t to the
	Protective		Order	in this	matter	but	has	withdrawn	the		designation
Exhibit 84	January	7,	2011 ,	Rapid		Response	Team	memo,		JPM	-SDNYLIT
	00127930		-00127932,		pro	duced by		JPMorgan	in this	Action,	and	prev iously
	marked	as	Erdoes	Exhibit	24	at	deposition		JPMorgan		initially	designated this
	document		Confidential		pursuan	t	to the	Protective		Order in	this	matter but has
	withdrawn		the	designation
Exhibit 85	Document		at	JPM		-SDNYLIT		-00230825		-00230830,	pro	duced by
	JPMorgan	in	this	Action,		designated		Confidential		pursuan	t to the	Protective
	Order in	this	matter	and	filed	under	seal		[Sealed]
Exhibit 86	Document		at	JPM		-SDNYLIT		-00036884		-00036890,	pro	duced by
	JPMorgan		in this	Action,		designated		Confidential		by	JPMorgan	pursuan t to the
	Protective		Order	in this	matter	and	filed	under	seal	[Sealed]
Exhibit 87	Document		at	JPM		-SDNYLIT	-W		-00019086	-00019096,	pro	duced by
	JPMorgan		in this	Action,		and prev	iously		marked as	McCleerey		Exhibit 33 at
	deposition			Designated		Confidential	by		JPMorgan	pursuan	t to the	Protective
	Order in	this		matter	and fi	led under	seal		[Sealed]
Exhibit 88	Transcript		excerp	ts of		Deposition	of	former	CEO	of	Private	Bank John
	Duffy,	taken	July	13 ,	2023 ,	in this	Action		Designated		Confidential	by
	JPMorgan		pursuan	t to	the	Protective		Order	in this	matter	and filed	under seal
Exhibit 89	Document		at		JPM	-SDNYLIT		-00006049		-00006050,	pro	duced by '
	JPMorgan		in this	Action,		designated		Confidential		by	JPMorgan	pursuan t to the
	Protective		Order	in this		matter	and filed	under	seal	[Sealed]
Exhibit •90	November		9,	2010,	email,		JPM	-SDNYLIT		-00010814		-0001080815,
pro	duced		by	JPMorgan	in	this	Action,	and	prev iously		marked as	Exhibit
37	at	deposition			JPMorgan	initially		designated	this	document		Confidential
	pursuan	t to	the	Protective		Order	in this	matter	but	has	withdrawn	the
	designation		in	par t and	the	document	is	filed	under	seal in	par t	[Sealed in
par	t]

Exhibit 91 July	26,,2006,	email,		NEJPM		-SDNYLIT			-00099335produced s			by JPMorgan
in this	Action,	and	Palm		Beach Post	article	by	Lam(			After	long pro be,
Palm	Beach	billionaire		faces		solicitation	charge,	pu		blishedJuly		26, 2006, at
http://www						.palmbeachpostcom/pbccentrallcontentflocal						new/epaper/2006/07/2
6/slb		EPSTE1N_0726		.html,	accessed		March	15,	2023	through
latfweb	.archive				.org/web/20060929041447,				together	prev	iously	marked as
	=Exhibit	5 at		deposition		JPMorgan		initially	designated		this	document
	Confidential	pursuan	t	to the	Protective		Order	in this	matter	but	has	withdrawn
the	designation	in	par t	and	the	document	is fi	led	under	seal in	par t	[Sealed in
par t]
Exhibit 92 September	20,	2007,		entails,		JPM		-SDNYLIT		-000099500,		JPM
SDNYLIT		-000099501		, JPM		-SDNYLIT		-00390951	, JPM		-SDNYLIT
00390952,	pro	duced	by		JPMorgan	in this		Action,	and	prev	iously	marked as
Staley	Exhibit	14		JPMorgan	initially		designated		these	documents		Confidential
pursuan	t to	the	Protective		Otder	in this	matter	but	has	withdrawn		the
	designation in	par	t and	the	documents	are	fi	led under	seal	in	par t	[Sealed in
par t]
Exhibit 93 June	17, 2013,		email	and	attachment,		=JPM		-SDNYLIT		-00194342
00194344,	pro	duced	by		JPMorgan	in	&Thction,		and	prev	iously	marked as
DeLuca	Exhibit	23	at		deposition	JPMorgan		initially		designated		this document
	Confidential	pursuan	t	to	the	Protective	Order	in this		matter	but has	withdrawn
the	designation	in	par t	and	the	document	is fi	led	under	seal in	par	t [Sealed in
par t]
Exhibit 94 Jeffrey	Epstein's		2007	Non		-Prosecution		Agreement,
JDoe	JPMC		003010		-003023,	pro duced	by	Plainti	'	Jane a	oe in	this Action,
and	prev iously		marked	as	Erdoes	Exhibit	39	in	deposition
Exhibit 95 Oct	10, 2007,		email	and	attachment,			JPM	-SDNYL1T			-00099526
	00099528, pro		duced	by	JPMorgan	in	s	Action,	and	prev	iously	marked as
	McCleerey	Exhibit	6	at	deposition		JPMorgan		initially	designated		this document
	Confidential	pursuan	t	to	the	Protective	Order	in	this	matter	but has	withdrawn
the	designation	in	par t	and	the	document	is fi	led	under	seal	in par	t [Sealed in
par t]
Exhibit 96 July	1 , 2008,	email	and		attachment,	=		JPM	-SDNYLIT			-00002952
	00002955,	pro	duced	by	JPMorgan		itrAction,		and	prev	iously	marked as
Erdoes	Exhibit	17	at		deposition	JPMorgan		initially		designated		this document'
	Confidential	pursuan	t	to	the	Protective	Order	in	this	matter	but	has withdrawn
the	designation
I ixhibit 97 July	15, 2008,		email	and	multiple		attachments,			JPM		-SDNYLIT
	00003026		-00003035,produced			by	JPMorgan	in	this	Action,	and	prev iously

		marked	as	Exhibit	27	at	deposition	JPMorgan	initially		designated	this
		document		Confidential	pursuan	t to	the	Protective	Order in	this matter	but	has
		withdrawn	the	designation		in par t	and the	document	is filed	under	seal in	par t
		[Sealed	in par t]
Exhibit	98	Sept	9, 2010,	email,		JPM	-SDNYLIT	-00229703	, pro	duced	by	JPMorgan
		in this	Action,	and prev	iously	marked	as	Cutler	Exhibit 9	at deposition
		JPMorgan	initially		designated	this	document		Confidential	pursuan	t to	the
		Protective	Order	in this		matter but	has	withdrawn	the	designation	in par	t and the
		document	is filed	under	seal	in par	t [Sealed	in par	t]
Exhibit	99	Transcript	excerp	ts of	the	Deposition	of	former	General	Counsel		Stephen
		Cutler,	taken	May 24,	2023,	in this	Action		Designated	Confidential	in	par t by
		JPMorgan	pursuan	t to	the	Protective	Order	in this	matter	and filed	under	seal in
		par t	[Sealed in	par t]
Exhibit	100	March	16, 2011	, email,		JPM	-SDNYLIT		-00274527,00274531		,	pro duced
		by	JPMorgan in	this	Action,	and	prev iously	marked	as Cutler	Exhibit	29	at
		deposition		JPMorgan	initially		designated	this	document	Confidential		pursuan t
		to the	Protective	Order	in	this matter	but	has	withdrawn the	designation
Exhibit	101	Oct 6,	2007,	article,		JIPM	-SDNYLIT		-00036593, pro	duced	by	JPMorgan
		in this	Action,	and	prev	iously	marked as		Exhibit 24	at	deposition
		JPMorgan	initially		designated	this	document		Confidential	pursuan	t to	the
		Protective	Order	in	this	matter but	has	withdrawn	the	designation
Exhibit	102	Oct	26, 2007,	email,		JPM	-SDNYLIT		-00001962	-00001965,	pro	duced by
		JPMorgan	in	this	Action,	and prev	iously	marked	as	Exhibit	23 at
		deposition		JPMorgan		initially	designated	this	document	Confidential		pursuan t
		to the	Protective	Order	in	this matter	but	has	withdrawn the		designation
Exhibit	103	Document	at		JPM	-SDNYLIT		-00002155,	pro duced	by	JPMorgan	in this
		Action,	designated		Confidential		by	JPMorgan	pursuan t the	Protective		Order in
		this	matter and	filed	under	seal	[Sealed]
Exhibit	104	July	31 , 2010,	email,		JPM	-SDNYLIT		-00100251 ,	pro duced	by	JPMorgan
		in this	Action,	and	prev	iously	marked as	Erdoes	Exhibit 23	at	deposition
			JPMorgan	initially	designated	this	document		Confidential	pursuan	t to	the
		Protective	Order	in	this	matter but	has	withdrawn	the	designation
	Exhibit 105		Document at		JPM	-SDNYLIT		-00011902,	pro duced	by	JPMorgan	in this
		Action,	designated		confidential	by	JPMorgan		pursuan t to	the	Protective	Order in
		this	matter and	filed	under	seal	[Sealed]
	Exhibit 106	August	4, 2010,	article,		JPM		-SDNYLIT	-00036596	-00036598,		pro duced
		by	JPMorgan	in this	Action,	and	prev	iously marked	as		Exhibit	13 at
			deposition	JPMorgan		initially	designated	this	document	Confidential		pursuan t

to the	Protective		Order	in	this	matter	but has	withdrawn		the	designation	in par t
and the		document	is fi	led	under	seal in	par t	[Sealed	in	par t]
Exhibit 107 March	7, 2011	,	email	and	attachment,		=JPM		-SDNYLIT		-00013499
00013500,	pro		duced	by	JPMorgan	in	67	Attion,	and prev	iously	marked	as
Erdoes	Exhibit		26 at	deposition		JPMorgan		initially		designated	this	document
	Confidential		pursuan t	to the		Protective	Order	in this	matter	but	has	withdrawn
the	designation
Exhibit 108 Document	at		MIJPM		-SDNYLIT		-00751685	, pro	duced	by	JPMorgan	in this
Action,		designated		Confidential		by	JPMorgan	pursuan	t	to the	Protective	Order
in this	matter	and	filed	under	seal		[Sealed]
Exhibit 109 Document	at	,	IJPM		-SDNYLIT		-00751686,		pro duced	by	JPMorgan	in this
Action,	designs			Confidential		by	JPMorgan	pursuan	t	to the	Protective	Order
in this	matter	and	filed	under	seal		[Sealed]
Exhibit 110 Article	by	Dareh		Gregorian,		Second	Girl Sues	Mogul,		New York	Post	(February
7,	2008),		https://nypost			.com/2008/02/07/second		-g	irl -sues	-mogul/		(accessed
July	11 , 2023)
Exhibit 111	Intentionally	left	blank
Exhibit 112 Due	Diligence		Report,		JPM		-SDNYLIT		-00036258	-00036263,		pro duced
by	JPMorgan	in	this	Action,	and	prev	iously	marked	as	Pearn	Exhibit	17 at
deposition			JPMorgan		initially	designated	this		document		Confidential	pursuan t
to the	Protective		Order	in	this	matter	but has		withdrawn	the	designation	in par t
and	the	document	is	filed	under	seal	in par t	[Sealed	in	par t]
Exhibit 113 October	22	—	December	21	, 2010,	email	thread,	=		JPM	-SDNYLIT
00194018		-00194021		, pro	duced	by	JPMorgan	in	Maction,	and	prev	iously
marked	as	DeLuca		Exhibit	7 at	deposition		JPMorgan		initially	designated	this
	document		Confidential		pursuan	t to the	Protective		Order	in this	matter	but has
	withdrawn	the	designation
Exhibit 114	December	22,	2010,	email,		JPM		-SDNYLIT		-00152738	-00152742,
pro	duced by		JPMorgan,		and prev	iously	marked	as	DeLuca		Exhibit 8	at
	deposition		JPMorgan		initially	designated	this		document		Confidential	pursuan t
to the		Protective	Order	in	this	matter	but has		withdrawn	the	designation
Exhibit 115	December	23 ,	2010,	email,		JPM		-SDNYLIT		-00204777,	pro	duced by
	JPMorgan	in this		Action,	an	prev	iously	marked	as	DeLuca	Exhibit	10 at
	deposition		JPMorgan		initially	designated		this	document		Confidential	pursuan t
to the		Protective	Order	in	this	matter	but has		withdrawn	the	designation	while
	retaining its		original		redactions	to the	document

Exhibit 116 January	4,	2011 ,	email,	ill	.JPM		-SDNYLIT		-00011967		-00011968,	pro duced
by	JPMorgan	in	this	Action,	and	prev	iously	marked	as		IllExhibit	40 at
deposition			JPMorgan	initially		designated	this			documentConfidential		pursuan t
to the	Protective		Order	in	this	matter	but has	withdrawn		the	designation
Exhibit 117 January	6,	2011	, email,	JPM		-SDNYLIT		-00194062		-00194063,	pro	duced by
JPMorgan	in	this		Action,	and prev		iously	marked as	Ryan	Exhibit	6	at
deposition			JPMorgan	initially		designated	this		document		Confidential	pursuan t
to the	Protective		Order	in	this	matter	but has		withdrawn	the	designation
Exhibit 118 January	10,	2011	,	email and		attachments,	JPM		-SDN'YLIT		-00157065	_R
00157082,		pro	duced	by	JPMorgan	in	this	Action,	and	prev iously		marked as
Ryan	Exhibit	8	at	deposition		JPMorgan		initially	designated		this	document
	Confidential		pursuan	t to the		Protective	Order	in this		matter but	has	withdrawn
the	designation		in par	t and	the	document	is fi	led	under	seal in	par t	[Sealed in
par t]
Exhibit 119	Transcript	excerp	ts	of the		Deposition	of	former	head	of	Compliance	at
	JPMorgan,		William		Langford,	taken	on	May 3 ,	2023,	in this	Action	J
	JPMorgan	has	withdrawn		its	designation	of		Confidential	for	the	testimony
	contained in		these	excerp ts
Exhibit 120	Transcript	excerp	ts	of the		Deposition	of the	Former		Managing		Director,
Global	FIU		Investigations,			Phillip	DeLuca,	taken	on	April	19, 2023,	in this
Action		JPMorgan		has	withdrawn	its	designation		of	Confidential	for	the
	testimony		contained	in these		excerp ts
Exhibit 121 March	12,	2013,	email,			JPM	-SDLIT	-00194272		-00194273	,	pro duced by
	JPMorgan	in this		Action,	and	prev	iously	marked	as	DeLuca	Exhibit	22 at
	deposition		JPMorgan		initially	designated		this	document		Confidential	pursuan t
to the	Protective		Order	in	this	matter	but has		withdrawn	the	designation	in pan
and	the	document	is	filed	under	seal	in par t	[Sealed	in	par t]
Exhibit 122 "Bear	Steams		Colla	ses	Sold	to J .P		Chase	"	available:
chase,	accessed		June	23 ,	2023
Exhibit 123	Transcript	excerp	ts	of the		Deposition	of	CEO of	Asset	Wealth		Management,
Mary	Erdoes,		taken	March	15,	2023,	in this	Action,		designated		confidential in
par t	by	JPMorgan		pursuan	t to	the	Protective	Order	in	this	matter and	filed under
seal	in par t		[Sealed	in par	t]
Exhibit 124 Due	Diligence		Report,			JPM	-SDNYLIT			-0003717140037177,		pro duced
by	JPMorgan		in this	Action,		and prev	iously	marked	as		Exhibit	34 at
	deposition		JPMorgan		initially		designated	this		documentConfidential		pursuan t

	to the Protective Order in this matter but has withdrawn the designation in part and the document is filed under seal in part. <b>[Sealed in part]</b>
Exhibit 125	Document at [REDACTED] <b>JPM-SDNYLIT-00373074-00373076</b> , produced by JPMorgan in this Action, designated confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. <b>[Sealed]</b>
Exhibit 126	Arthur Middlemiss LinkedIn Profile, <a href="https://www.linkedin.com/in/arthur-middlemiss-341a6b11/">https://www.linkedin.com/in/arthur-middlemiss-341a6b11/</a> .
Exhibit 127	January 10, 2011, email, <b>JPM-SDNYLIT-00157192-00157193</b> , produced by JPMorgan in this Action, and previously marked as Langford Exhibit 37 at deposition. JPMorgan initially designated this document Confidential pursuant to the Protective Order in this matter but has withdrawn the designation while retaining its original redactions to the document.
Exhibit 128	Document at [REDACTED] <b>JPM-SDNYLIT-00373247</b> , produced by JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. <b>[Sealed]</b>
Exhibit 129	Document at [REDACTED] <b>JPM-SDNYLIT-00373248-00373252</b> , produced by JPMorgan in this Action, designated confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. <b>[Sealed]</b>
Exhibit 130	Aug. 27, 2006, email, [REDACTED] <b>JPM-SDNYLIT-00099337</b> , produced by JPMorgan in this Action, and previously marked as Erdoes Exhibit 10 at deposition. JPMorgan initially designated this document Confidential pursuant to the Protective Order in this matter but has withdrawn the designation in part and the document is filed under seal in part. <b>[Sealed in part]</b>
Exhibit 131	Document at [REDACTED] <b>JPM-SDNYLIT-00106627</b> , produced by JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. <b>[Sealed]</b>
Exhibit 132	Article, <i>The Truth About Jeffrey Epstein and 'Vanity Fair'</i> , posted by Chaire, <a href="http://www.gawker.com/302773/the-truth-about-jeffrey-epstein-and-vanity-fair">http://www.gawker.com/302773/the-truth-about-jeffrey-epstein-and-vanity-fair</a> , accessed June 27, 2023.
Exhibit 133	May 28, 2008, email, [REDACTED] <b>JPM-SDNYLIT-00134475</b> , produced by JPMorgan in this Action, and previously marked as Erdoes Exhibit 44 at deposition. JPMorgan initially designated this document Confidential pursuant to the Protective Order in this matter but has withdrawn the designation in part and the document is filed under seal in part. <b>[Sealed in part]</b>
Exhibit 134	Article by John M. Cunningham, <i>Miley Cyrus</i> , <a href="http://www.britanica.com/biography/Miley-Cyrus">http://www.britanica.com/biography/Miley-Cyrus</a> , accessed July 12, 2023.

Exhibit 135 February	9,	2011	, email,			JPM	-SDNYLIT		-00453044,	pro	duced	by
JPMorgan	in	this	Action,		and prev	iously	marked	as	Ryan	Exhibit	13	at
deposition			JPMorgan	initially		designated	this		document	Confidential		pursuan t
to the	Ptotective		Order	in this		matter	but has	withdrawn		the	designation
Exhibit 136 Article,	Law	&	Order		Commemorates		Jeffrey	Epstein's		Taste	for Teen	Hookers,
Gawker,		https://www		.gawker			.coin/5751094/law			-order-commemorates		-jeffrey
eps	teins -taste		-for-teen	-hookers,		accessed	June	30,	2023
Exhibit 137	November	29,	2011 ,	email,		JPM		-SDNYLIT		-00100689,	pro	duced by
	JPMorgan	in this	Action,		and	prev	iously	marked as	DeLuca		Exhibit	20 at
deposition			!Morgan	initially		designated	this		document		Confidential	pursuan t
to the	Protective		Order	in	this	matter	but has	withdrawn		the	designation	in par t
and	the	document	is fi	led	under	seal	in par t	[Sealed	in	par t]
Exhibit 138 June	17, 2013,		email,		JPM		-SDNYLIT	-00100935		-00100936,		pro duced
by	JPMorgan		in this	Action,	and	prev	iously	marked	as	Erdoes	Exhibit	29 at
	deposition		JPMorgan	initially		designated	this		document		Confidential	pursuan t
to the	Protective		Order	in	this	matter	but has		withdrawn	the	designation
Exhibit 139	September	13 ,	2012,	email,		JPM		-SDNYLIT		-00755203 ,	pro	duced by
	JPMorgan	in	this	Action,	and	prev	iously	marked as	Staley	Exhibit	19	at
	deposition		JPMorgan	initially		designated	this		document		Confidential	pursuan t
to the		Protective	Order	in	this	matter	but has		withdrawn	the	designation
Exhibit 140 July	10, 2010,		email,		JPM		-SDNYLIT	-00008669		-00008670,		pro duced by
	JPMorgan	in	this	Action,	and	marked	as Staley		Exhibit	35 at	deposition
	JPMorgan		initially	designated		this	document		Confidential	pursuan	t	to the
	Protective	Order	in	this	matter	but has	withdrawn		the	designation
Exhibit 141 January	23 ,		2008,	email,		JPM	-SDNYLIT		-00006171	, pro	duced	by
	JPMorgan	in	this	Action,	and	prev	iously	marked	as	Dimon	Exhibit	11 at
	deposition		JPMorgan		initially	designated	this		document		Confidential	pursuan t
to the		Protective	Order	in	this	matter	but has		withdrawn	the	designation
Exhibit 142	September	1 ,	2009,	email,			ESTATE		JPM002773	, pro	duced	by nonpar ty
The	Estate	of	Jeffrey	E	Epstein	in this	Action,	and	prev	iously	marked	as Staley
Exhibit	36	at	Deposition		The	Estate	initially		designated	this	document
	Confidential		pursuan	t to	the	Protective	Order	in	this	matter but	has	withdrawn
the	designation		in par	t and	the	document	is	filed	under	seal in	par t	[Sealed in
par	t]
Exhibit 143	December	20,	2009,	email	and		attachment,		JPM	-SDNYLIT		-00006791
	00006792,	pro	duced	by	JPMorgan	in	this	Action,	and	prev iously		marked as
Staley	Exhibit		37 at	deposition			JPMorgan	initially		designated	this	document
	Confidential		pursuan	t to	the	Protective	Order	in	this	matter but	has	withdrawn

the	designation	in	par t	and	the	document is	filed	under seal	in par t	[Sealed in
par	t]
Exhibit 144	Document	at	JPM		-SDNYLIT	-00901998		-00902019,	pro duced	by
	JPMorgan	in this	Action,	and	marked	Staley	Exhibit	21 at	deposition	JPMorgan
initially		designated	this		document	Confidential		pursuan t to	the	Protective Order
in	this matter	but	has	withdrawn		the	designation in	par t and	the	document is
filed	under	seal in	par t		[Sealed in	par t]
Exhibit 145	December 5,	2009,		email	and	attachment,	NERM	-SDNYLIT		-00006715
	00006716,	pro duced		by	JPMorgan	in this	Action,	and marked	as	Staley Exhibit
38	at deposition			JPMorgan	initially		designated this	document		Confidential
	pursuan t to	the	Protective		Order	in this	matter but	has	withdrawn	the
	designation	in par	t and	the	document	is fi	led under	seal in	par t	[Sealed in
par	t]
Exhibit 146	Document	at		JEM	-SDNYLIT		-00006718	-00006719,	pro	duced by
	JPMorgan	in this	Action,		designated		Confidential	by	JPMorgan	pursuan t to the
	Protective	Order	in	this	matter and	filed	under seal	[Sealed]
Exhibit 147	Department	of	Financial		Services	announcement:			"Superintendent	Lacewell
	Announces	DFS	Imposes		$150	Million	Penalty on	Deutsche	Bank	in
	Connection	with	Bank's		Relationship	with	Jeffrey	Epstein	and	Correspondent
	Relationships	with		Danke	Estonia	and	FBME Bank	"	Previously	marked as
Cutler	Exhibit	39	at	deposition
Exhibit 148	Consent	Order, In	the	Matter	of	Deutsche	BankAG,	et al ,	New	York State
	Department	of	Financial		Services,	signed	July 6,	2020	Previously	marked as
	Cutler Exhibit	40	at	deposition
Exhibit 149	Excerpt of	document		at	JPM	-SDNYLIT		-00921097,	pro	duced in Excel
	format by	JPMorgan		in the	Action	This	excerp t	was created	to	show relevant
rows	and	columns	by	fi	ltering for	spec ific	"Beneficiary		Normalized"	entries
and	by hiding		multiple		columns	Designated		Confidential	by	JPMorgan
	pursuan t to	the	Protective		Order	in this	matter and	filed	under seal	[Sealed]
Exhibit 150
Bank		statement	for	account	ending	in 6312,		JPM	-SDNYLIT	-00085024
	00085031 ,	pro	duced	by	JPMorgan	in this	Action,	designated		Confidential by
	JPMorgan	pursuan	t	to the	Protective	Order	in this	matter	and filed	under seal
Exhibit 151	Bank	statement	for	account	ending	in 4324,		JPM	-SDNYLIT	-00076877
	00076880,	pro	duced	by	JPMorgan	in this	Action,	designated		Confidential by
	JPMorgan	pursuan	t	to the	Protective	Order	in this	matter	and filed	under seal

Exhibit 152 Index	of	account		statements	for	Epstein's	JPMorgan		account ending	in 0663,
pro	duced	by	JPMorgan	in	this Action	*
Frhibit 153	Index	of	account statements		for The	C .O	.U .Q	Foundation's	JPMorgan	account
	ending	in 1565,	pro	duced	by JPMorgan	in	this	Action .'
Exhibit 154	Compilation		of wire		instructions,		JPM	-SDNYLIT	-00095431	-95432;
JPM		-SDNYLIT		-00095431	-95432;	JPM		-SDNYLIT	-00095471;	JPM
	SDNYLIT		-00095709;	JPM	-SDNYLIT		-00096355;	JPM	-SDNYLIT
	00097240;		JPM	-SDNYLIT	-00097437		-97438;	JPM	-SDNYLIT	-00097820
	97821 ,	pro	duced by	JPMorgan	in	this Action		Designated	Confidential	by
	JPMorgan		pursuan	t to the	Protective	Order	in	this matter	and filed	under seal
Exhibit 155	Account		statement	summary	for	account	ending	in 4810,		JPM
	SDNYLIT		-00091214,	pro	duced	by	JPMorgan	in this	Action,	designated
	Confidential		by	JPMorgan	pursuan	t to the		Protective	Order in this	matter and
fi	led	under	seal	[Sealed]
Exhibit 156	Documents		related	to	Epstein's	2012 g ift	tax	return,	MP	-00000778
	00000832832,		pro	duced	by nonpar	ty Marks		Paneth in	this Action,	designated
	Confidential		pursuan	t to	the Protective		Order	in this	matter and fi	led under seal
Exhibit 157	November		20, 2012,	Private	Bank	Client	Cash	Transaction	Guidelines,
JPM		-SDNYLIT		-00130224	-00130226,		pro duced	by	JPMorgan in	this Action,
and	prev	iously		marked as		Exhibit	32 at	deposition	JPMorgan	initially
	designated		this	document	Confidential		pursuan	t to the	Protective	Order in this
	matter	but	has	withdrawn	the	designation
Exhibit 158	Excerpt	of	document,		JPM	-SDNYLIT		-W -00017133	W	-00017134,
	JPM	-SDNYLIT	-W		-00017206 —	W	-00017210,	pro duced	by	JPMorgan in this
	Action,		designated		Confidential	by	JPMorgan	pursuan t	to the	Protective Order
in	this	matter	and	filed	under seal	[Sealed]
Exhibit 159	Document		at	JPM	-SDNYLIT	-W	-00000001		-00000002,	JPM -SDNYLIT
	—W	-00000175		-00000182	(excerpts),	pro	duced	by	JPMorgan in	this Action,
	prev	iously	marked	as	Dimon Exhibit	132	at	deposition	Designated	Confidential
by		JPMorgan	pursuan	t to	the	Protective	Order	in this	matter and	filed under
	seal	[Sealed]
Exhibit 160	Transcript		excerp	ts of the	Deposition	of	former	Private	Banker	Paul Morris
	taken	April	18,	2023, in	this Action		Designated		Confidential in	par t by
	JPMorgan		pursuan	t to the	Protective	Order	in	this matter	and fi	led under seal in
par	t	[Sealed	in par	t]

Exhibit 161 Document,			"Wealth	Management		Top	25	Investor	Clients,"	-JPM
SDNYLIT			-00133088,	pro	duced	in	Excel	format by	JPMorgan	in this	Action,
and	prev iously		marked	as	Staley	Exhibit	3 at	deposition	JPMorgan		initially
	designated	this	document			Confidential	pursuan	t to the	Protective	Order	in this
matter	but	has	withdrawn	the		designation	in	par t and	the document	is fi	led under
seal	in par t		[Sealed	in par	t]
Exhibit 162 October	2,	2006,	email,			JPM	-SDNYLIT	-00001091		-00001099,	pro duced
by	JPMorgan	in	this	Action,	and	prev	iously	marked as	Erdoes	Exhibit	5 at
depositibn			JPMorgan	initially		designated	this	document		Confidential	pursuan t
to the	Protective		Order	in	this	matter	but has	withdrawn	the	designation	in par t
and	the	document	is	filed	under	seal	in par t	[Sealed	in par t]
Exhibit 163 April	20,	2004,	email,		JPM		-SDNYLIT		-00105(aproduced	by
	JPMorgan	in this	Action,		and prev		iously marked	as	Exhibit	9 at
	deposition		JPMorgan	initially		designated	this	document		Confidential	pursuan t
to the	Protective		Order	in this		matter	but has	withdrawn	the	designation
Exhibit 164 February	24,		2005,	email,		JPM	-SDNYLIT		-00448615	-00448616,
pro	duced by		JPMorgan	in	this	Action,	and	prev iously	marked	as Staley	Exhibit
5 at	deposition		JPMorgan		initially		designated	this	document	Confidential
pursuan	t to	the	Protective		Order	in this	matter	but has	withdrawn	the
	designation	in	par t and	the		document	is filed	under seal	in par t	[Sealed	in
par t]
Exhibit 165 July	15, 2008,		Rapid	Response		Team		memorandum,	JPM		-SDNYLIT
	00127944,	pro	duced	by	JPMorgan	in	this	Action, and	prev iously	marked	as
Erdoes		Exhibit	18 at	deposition			JPMorgan	initially	designated	this	document
	Confidential		pursuan	t to the		Protective	Order	in this	matter but	has	withdrawn
the	designation
Exhibit 166	Document	at			JPMSDNYLIT		-00003755	-00003758,	pro	duced	by
	JPMorgan	in	this	Action,	designated		Confidential	by	JPMorgan	pursuan	t to the
	Protective	Order	in	this	matter	and	filed under	seal	[Sealed]
Exhibit 167	Document	at		JPM	-SDNYLIT		-00011654	-00011655,	pro	duced	by
	JPMorgan	in	this	Action,		designated	Confidential	by	JPMorgan	pursuan	t to the
	Protective	Order	in	this	matter	and fi	led under	seal	[Sealed]
Exhibit 168	Document	at		JPM	-SDNYLIT		-00754975	-00754979,	pro	duced	by
	JPMorgan	in	this	Action,	and	prev	iously	marked Staley	Exhibit	4 at	deposition
	JPMorgan		initially	designated		this	document	Confidential	pursuan	t to	the
	Protective	Order	in	this	matter	but has		withdrawn the	designation	in	par t and the
	document	is fi	led	under seal	in	par t	[Sealed	in par t]

Exhibit 169	July 3 ,	2013,	email,		JPM	-SDNYLIT		-00029230,	pro duced	by	JPMorgan
	in this	Action,	and	prev iously		marked as	Nelson	Exhibit	7 at	deposition
	JPMorgan		initially	designated	this		document	Confidential	pursuan	t to	the
	Protective		Order in	this	matter but	has	withdrawn	the	designation
Exhibit 170	Document	at		JPM	-SDNYLIT		-00394015	-00394017,	pro	duced	by
	JPMorgan	in	this	Action,	designated		Confidential	by	JPMorgan	pursuan	t to the
	Protective		Order in	this	matter and	filed	under	seal [Sealed]
Exhibit 171	Transcript		excerp	ts of the	Deposition		of Justin	Nelson,	taken	April	21 , 2023 , in
	this	Action	JPMorgan	has	withdrawn		its designation	of	Confidential		for the
	testimony		contained	in these	excerp	ts
Exhibit 172	Third	-Party	Defendant	James	E	Staley's	Responses	and	Objections		to the
	Government		of the	United	States	Virgin	Islands'	First	Set of	Interrogatories,
	dated	April	20, 2023
Exhibit 173	January	23 ,	2008,	email,		JPM	-SDNYLIT	-00002152,	pro	duced	by
	JPMorgan		in this	Action,	and prev	iously	marked	as Dimon		Exhibit	113 at
	deposition		JPMorgan		initially	designated	this	document	as	Confidential
	pursuan	t to	the	Protective	Order	in this	matter	but has	withdrawn	the
	designation		in par	t and the	document	is	filed	under seal	in par t	[Sealed	in
	par t]
Exhibit 174	June 5,	2009,	email,		JPM	-SDNYLIT		-00005959,	pro duced	by	JPMorgan
	in this	Action		Designated		Confidential	by	JPMorgan	pursuan t	to the	Protective
	Order	in this	matter	and fi	led	under seal	[Sealed]
Exhibit 175	Excerpt	of	document	at		JPM	-SDNYLIT	-00907707,	pro	duced	in Excel
	format	pro	duced	by JPMorgan		in this	Action,	designated		Confidential	by
	JPMorgan		pursuan	t to the	Protective		Order in	this Matter	and fi	led	under seal
Exhibit 176	June	18,	2009,	email,	JPM		-SDNYLIT	-00006005,	pro	duced	by
	JPMorgan		in this	Action,	and prev	iously	marked	as	Dimon	Exhibit	101 at
	deposition		JPMorgan		initially	designated	this	document		Confidential	pursuan t
	to the		Protective	Order in	this	matter	but has	withdrawn	the	designation
Exhibit 177	Document		at	JPM	-SDNYLIT		-00004763	, pro	duced by	JPMorgan	in this
	Action,		designated	Confidential		by	JPMorgan	pursuan t	to the	Protective	Order
	in this	matter	and	filed	under seal		[Sealed]
Exhibit 178	Document		at	JPM		-SDNYLff-00007534		-00007535,	pro	duced	by
	JPMorgan		in this	Action,	designated		Confidential	by	JPMorgan		pursuan t to the
	Protective		Order	in this	matter	and fi	led under	seal	[Sealed]

Exhibit 179 Document	at		JPM	-SDNYLIT		-00007970,	pro duced	by	JPMorgan	in this
Action,	designated	Confidential			by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and filed		under	seal [Sealed]
Exhibit 180 Document	at		JPM	-SDNYLIT		-00009703	, pro duced	by	JPMorgan	in this
Action,	designated	Confidential			by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and filed		under	seal	[Sealed]
Exhibit 181 December	2,	2010,	email,		ESTATE		006071 , pro	duced	by nonpar	ty The
Estate	of Jeffrey	E	Epstein	The	Estate	initially	designated	this	document
Confidential		pursuan	t to	the	Protective	Order	in this matter	but	has	withdrawn
the designation		in par	t	and the	document	is fi	led under	seal in	par t	[Sealed in
par	t]
Exhibit 182 Document	at		JPM	-SDNYLIT		-00011808,	pro duced	by	JPMorgan	in this
Action,	designated		Confidential		by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and fi	led	under	seal	[Sealed]
Exhibit 183 November	23,	2013,	email,			JPM -SDNYLIT	-00153462		-00153463,
pro duced	by	JPMorgan		in this	Action,	and prev	iously	marked	as Staley	Exhibit
13 at	deposition	JPMorgan		initially		designated	this document		Confidential
pursuan	t to the	Protective		Order	in	this matter	but has	withdrawn	the
Exhibit 184 Document	at		JPM	-SDNYLIT		-00102986,	pro duced	by	JPMorgan	in this
Action,	designated		Confidential		by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and filed		under	seal	[Sealed]
Exhibit 185 Document	at		JPM	-SDNYLIT		-00102892	-00102893,		pro duced	by
JPMorgan	in	this Action,		and	prev	iously marked		Exhibit	10	at deposition
JPMorgan	initially		designated		this	document	Confidential	pursuan		t to the
Protective	Order	in	this	matter	but	has withdrawn	the	designation	in	par t and the
document	is	filed under		seal	in par	t [Sealed	in par t]
Exhibit 186 Document	at		JPM	-SDNYLIT		-00000184_R	-00000186_R,			pro duced by
JPMorgan	in	this Action,		designated		Confidential	by	JPMorgan	pursuan	t to the
Protective	Order	in	this	matter	and	filed under	seal [Sealed]
Exhibit 187 Document	at		JPM	-SDNYLIT		-00099558	-00099560,		pro duced	by
JPMorgan	in	this Action,		designated		Confidential	by	JPMorgan	pursuan	t to the
Protective	Order	in	this	matter	and	filed under	seal [Sealed]
Exhibit 188 Documents		at	SB	-0001	-0006,	pro duced	by nonpar	ty	Sergey	Brin in this
Action,	designated		Confidential		pursuan	t to	the Protective	Order	in	this matter
and	filed under	seal	[Sealed]

Exhibit 189 Documents	at	AUBURN	-001	-AUBURN	-024,	pro	duced		by nonpar	ty
Larry	Page in this	Action,	designated	Confidential		pursuan		t to	the Protective
Order	in this matter	and filed	under	seal [Sealed]
Exhibit 190 July	23 , 2014,	KYC Summary,		JPM	-SDNYLIT	-00902708			-00902714,
pro duced	by JPMorgan	in	this Action,	and	prev iously	marked			as Staley	Exhibit
10 at	deposition	JPMorgan	initially	designated	this	document			Confidential
pursuan	t to the	Protective	Order in	this matter	but has	withdrawn			the
designation	in	par t and the	document	is fi	led under	seal	in	par	t [Sealed	in
par t]
Exhibit 191 Document	at	JPM -SDNYLIT		-00449185,	pro	duced		by	JPMorgan	in this
Action,	designated	Confidential	by	JPMorgan	pursuan	t	to	the	Protective	Order
in this	matter	and filed under	seal	[Sealed]
Exhibit 192 Document	at	JPM -SDNYLIT		-00390515,	pro	duced		by	JPMorgan	in this
Action,	designated	Confidential	by	JPMorgan	pursuan	t	to	the	Protective	Order
in this	matter	and filed under	seal	[Sealed]
Exhibit 193 Document	at	JPM -SDNYLIT		-00390516,	pro	duced		by	JPMorgan	in this
Action,	designated	Confidential	by	JPMorgan	pursuan	t	to	the	Protective	Order
in this	matter	and filed under	seal	[Sealed]
Exhibit 194 Document	at	JPM -SDNYLIT		-00390517,	pro	duced		by	JPMorgan	in this
Action,	designated	Confidential	by	JPMorgan	pursuan	t	to	the	Protective	Order
in this	matter	and filed under	seal	[Sealed]
Exhibit 195 Document	at	JPM -SDNYLIT		-00390519,	pro	duced		by	JPMorgan	in this
Action,	designated	Confidential	by	JPMorgan	pursuan	t	to	the	Protective	Order
in this	matter	and filed under	seal	[Seated]
Exhibit 196 October	26, 2006,	email,	IPMSDNYLIT		-00099356,				pro duced	by
JPMorgan	in	this Action,	and prev	iously	marked as	Staley		Exhibit	9	at
deposition	JPMorgan	initially	designated		this document			Confidential		pursuan t
to the	Protective	Order in	this matter	but	has withdrawn		the		designation
Exhibit 197 Document	at	JPM -SDNYLIT		-00390520	-00390521			,	pro duced	by
JPMorgan	in	this Action,	designated	Confidential		by JPMorgan			pursuan	t to the
Protective	Order	in this matter	and	filed	under seal	[Sealed]
Exhibit 198 Document	at	JPM -SDNYLIT		-00390522	-00390523,				pro duced	by
JPMorgan	in	this Action,	designated	Confidential		by JPMorgan			pursuan	t to the
Protective	Order	in this matter	and	filed	under seal	[Sealed]
Exhibit 199 Document	at	JPM -SDNYLIT		-00390590	-00390591			,	pro duced	by
JPMorgan	in	this Action,	designated	Confidential		by JPMorgan			pursuan	t to the
Protective	Order	in this matter	and	filed	under seal	[Sealed]

Exhibit 200 Document	at		JPM	-SDNYLIT		-00099423	, pro duced	by	JPMorgan	in this
Action,	designated	Confidential			by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and fi	led	under	seal	[Sealed]
Exhibit 201 Document	at		JPM	-SDNYLIT		-00134152,	pro duced	by	JPMorgan	in this
Action,	designated	Confidential			by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and fi	led	under	seal	[Sealed]
Exhibit 202 Document	at		JPM	-SDNYLIT		-00449668,	pro duced	by	JPMorgan	in this
Action,	designated		Confidential		by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and fi	led	under	seal	[Sealed]
Exhibit 203 Document	at		JPM	-SDNYLIT		-00449669	-00449672,	pro	duced	by
JPMorgan	in	this Action,		designated		Confidential	by	JPMorgan	pursuan	t to the
Protective	Order	in	this	matter	and	filed under	seal [Sealed]
Exhibit 204 Document	at		JPM	-SDNYLIT		-00390671	, pro duced	by	JPMorgan	in this
Action,	designated		Confidential		by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and fi	led	under	seal	[Sealed]
Exhibit 205 January	31 , 2007,	email,			JPM	-SDNYLIT	-00390720,		pro duced	by
JPMorgan	in	this Action,		designated		Confidential	by	JPMorgan	pursuan	t to the
Protective	Order	in	this	matter	and	filed under	seal [Sealed]
Exhibit 206 Document	at		JPM	-SDNYLIT		-00449037	-00449038,		pro duced	by
JPMorgan	in	this Action,		designated		Confidential	by	JPMorgan	pursuan	t to the
Protective	Order	in	this	matter	and	filed under	seal [Sealed]
Exhibit 207 Mahmoud	Difrawy		Linkedln		Profile,	available	at:
https://www		.linkedin	.com/in/mahrnoud			-difrawy
Exhibit 208 Document	at		JPM	-SDNYLIT		-00006724	-00006725,		pro duced	by
JPMorgan	in	this Action,		designated		Confidential	by	JPMorgan	pursuan	t to the
Protective	Order	in	this	matter	and	filed under	seal [Sealed]
Exhibit 209 December	8,	2009,	email,		ESTATE		JPM002897,	pro	duced	by nonpar ty
The	Estate of	Jeffrey	E	Epstein	in	this Action	The Estate	initially		designated
this	document	Confidential			pursuan	t to the	Protective	Order	in this	matter but
has	withdrawn	the	designation
Exhibit 210 Document	at		JPM	-SDNYLIT		-00006727,	pro	duced by	JPMorgan	in this
Action,	designated		Confidential		by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and	filed	under	seal	[Sealed]

Exhibit 211	Document at [REDACTED] <b>JPM-SDNYLIT-00006729</b> , produced by JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. [Sealed]
Exhibit 212	August 15, 2013, email, [REDACTED] <b>JPM-SDNYLIT-00101010-00101011</b> , produced by JPMorgan in this Action, and previously marked as Erdoes Exhibit 49 at deposition. JPMorgan initially designated this document Confidential pursuant to the Protective Order in this matter but has withdrawn the designation in part and the document is filed under seal in part. [Sealed in part]
Exhibit 213	July 10, 2012, email, [REDACTED] <b>JPM-SDNYLIT-00022569</b> , produced by JPMorgan in this Action, and previously marked as Erdoes Exhibit 31 at deposition. JPMorgan initially designated this document Confidential pursuant to the Protective Order in this matter but has withdrawn the designation in part and the document is filed under seal in part. [Sealed in part]
Exhibit 214	Document at [REDACTED] <b>JPM-SDNYLIT-00393112</b> , produced by JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. [Sealed]
Exhibit 215	Document at [REDACTED] <b>JPM-SDNYLIT-00028892-00028893</b> , produced by JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. [Sealed]
Exhibit 216	Document at [REDACTED] <b>JPM-SDNYLIT-00029911-00029913</b> , produced by JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. [Sealed]
Exhibit 217	Document at [REDACTED] <b>Apollo_VI_00000423</b> , produced by nonparty Apollo Global Management, Inc. in this Action, designated Confidential pursuant to the Protective Order in this matter and filed under seal. [Sealed]
Exhibit 218	Document at [REDACTED] <b>Apollo_VI_00000646</b> , produced by nonparty Apollo Global Management, Inc. in this Action, designated Confidential pursuant to the Protective Order in this matter and filed under seal. [Sealed]
Exhibit 219	March 23, 2011, email, [REDACTED] <b>JPM-SDNYLIT-00013841</b> , produced by JPMorgan in this Action, and previously marked as Staley Exhibit 12 at deposition. JPMorgan initially designated this document Confidential pursuant to the Protective Order in this matter but has withdrawn the designation in part and the document is filed under seal in part. [Sealed in part]
Exhibit 220	Document at [REDACTED] <b>JPM-SDNYLIT-00014260</b> , produced by JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. [Sealed]

Exhibit 221 Document	at		JPM	-SDNYLIT		-00017368,	pro duced	by	JPMorgan	in this
Action,	designated	Confidential			by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and filed		under	seal	[Sealed]
Exhibit 222 Excerpt	of JPMorgan		Chase		Bank,	N .A 's	Responses	and Objections		to Third
Party	Defendant's	First		Set of	Interrogatories,		dated May	18,	2023	Designated
Confidential	by	JPMorgan		pursuan		t to the	Protective	Order in	this	Matter and
filed	under seal	[Sealed]
Exhibit 223 Document	at		JPM	-SDNYLIT		-00032344	-00032346,	pro	duced	by
JPMorgan	in	this Action,		designated		Confidential	by	JPMorgan	pursuan	t to the
Protective	Order	in	this	matter	and	filed under	seal [Sealed]
Exhibit 224 Document	at		JPM	-SDNYLIT		-00032434	-00032435,		pro duced	by
JPMorgan	in	this Action,		designated		Confidential	by	JPMorgan	pursuan	t to the
Protective	Order	in	this	matter	and	filed under	seal [Sealed]
Exhibit 225 September	30,	2014,	email,			JPM -SDNYLIT	-00032511		-00032516,
pro duced	by	JPMorgan		in this	Action,	and	prev iously	marked	as Nelson	Exhibit
6 at	deposition	JPMorgan		initially		designated	this document		Confidential,
pursuan	t to the	Protective		Order	in	this matter	but has	withdrawn		the
Exhibit 226 April	21 , 2023,	email,			JPM	-SDNYLIT	-00032218	-0003220,		pro duced by
JPMorgan	in	this Action,		and	prev	iously marked	as Nelson		Exhibit	5 at
deposition	JPMorgan			initially	designated		this document	Confidential		pursuan t
to the	Protective	Order		in this	matter	but has	withdrawn	the	designation
Exhibit 227
Excerpt	of JPMorgan		Chase		Bank,	N .A 's	First Supplemental		Responses	and
Objections	to	Interrogatories			in Lieu	of Rule	30(b)(6)	Deposition		Testimony,
dated	April 14,	2023	JPMorgan		has	designated	por tions	of	the document
Confidential		pursuan	t	to the	Protective	Order	in this	matter	and the	document is
filed	under seal	in par	t
Exhibit 228 Document	at		JPM	-SDNYLIT		-00030644	-00030645,		pro duced	by
JPMorgan	in	this Action,		designated		Confidential	by	JPMorgan	pursuan	t to the
Protective	Order	in	this	matter	and	filed under	seal	[Sealed]
Exhibit 229 Document	at		JPM	-SDNYLIT		-00031300,	pro	duced	by JPMorgan	in this
Action,	designated		Confidential		by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and filed		under	seal	[Sealed]
Exhibit 230 Document	at		JPM	-SDNYLIT		-00394592	-00394593		, pro duced	by
JPMorgan	in	this Action,		designated		Confidential	by	JPMorgan	pursuan	t to the
Protective	Order	in	this	matter	and	filed under	seal	[Sealed]

Exhibit 231 Document	at		JPM	-SDNYLIT		-00032975	-00032976,	pro	duced	by
JPMorgan	in	this Action,		designated		Confidential	by JPMorgan		pursuan	t to the
Protective	Order	in	this	matter	and	filed under	seal [Sealed]
Exhibit 232 Document	at		JPM	-SDNYLIT		-00033177	-00033179,	pro	duced	by
JPMorgan	in	this Action,		designated		Confidential	by	JPMorgan	pursuan	t to the
Protective	Order	in	this	matter	and	filed under	seal [Sealed]
Exhibit 233 Document	at		JPM	-SDNYLIT		-00034618,	pro duced	by	JPMorgan	in this
Action,	designated		Confidential		by	JPMorgan	pursuan	t to,the	Protective	Order
in this	matter	and fi	led	under	seal	[Sealed]
Exhibit 234 JPMorgan	Chase	Bank,		N .A	's Supplemental		Responses	and	Objections	to Doe
Plaintiff's	First	Set	of	Interrogatories,		dated	April 11 ,	2023
Exhibit 235 Document	at		JPM	-SDNYLIT		-00233394,	pro duced	by	JPMorgan	in this
Action,	designated		Confidential		by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and	filed	under	seal	[Sealed]
Exhibit 236 Document	at		JPM	-SDNYLIT		-00233392,	pro duced	by	JPMorgan	in this
Action,	designated		Confidential		by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and	filed	under	seal	[Sealed]
Exhibit 237 Document	at		JPM	-SDNYLIT		-00791467,	pro duced	by	JPMorgan	in this
Action,	designated		Confidential		by	JPMorgan	pursuan	t to the	Protective	Order
in this	matter	and	filed	under	seal	[Sealed]
Exhibit 238 Document	at		JPM	-SDNYLIT		-00448060	-00448065,	pro	duced	by
JPMorgan	in	this	Action,	and	prev	iously marked	as Dimon	Exhibit		107 at
deposition	Designated			Confidential		by JPMorgan	pursuan	t to	the	Protective
Order	in this	matter	and	filed	under	seal	[Sealed]
Exhibit 239 January	3 , 2010,	document,				ESTATE_JPM010125		-010128,		pro duced by
nonpar	ty The	Estate		of Jeffrey	E	Epstein	in this Action	The	Estate	initially
designated	this	document		Confidential		pursuan	t to the	Protective	Order	in this
matter	but has	withdrawn		the	designation		in par t and	the document		is filed under
seal	in par t	[Sealed		in par	t]
Exhibit 240 Document	at		JPM	-SDNYLIT		-00154163	-00165164,		pro duced	by
JPMorgan	in	this	Action,	designated		Confidential	by	JPMorgan	pursuan	t to the
Protective	Order		in this	matter	and	filed under	seal	[Sealed]
Exhibit 241 February	15,	2005,	email,			JPM -SDNYLIT	-00448590		-00448591	,
pro	duced by	JPMorgan		in	this Action,	and	prev iously	marked	as Staley	Exhibit
1 at	deposition	JPMorgan			initially	designated	this document		Confidential
pursuan	t to	the Protective			Order	in this matter	but has	withdrawn		the

	designation		in par	t and	the	document	is fi	led	under seal in par	t [Sealed in
par t]
Exhibit 242 June	16,	2004,		email	and	attachments,		JPM	-SDNYLIT	-00448149
	00448196,	pro		duced by	JPMorgan	in	this	Action,	and prev	iously marked as
Staley		Exhibit	2	at	deposition	JPMorgan		initially	designated	this document
	Confidential		pursuan	t	to the	Protective		Order in	this matter	but has withdrawn
the	designation
Exhibit 243 Article	by		Andrew		Sorkin	and	Landon		Jr, J .P	Chase to
c	ire	Bank	One	in	58 Billion	Deal		New	York Times	January 14, 2004),
										-to acqu ire
	bank-one	-in	-58	-billion	-deal .html
Exhibit 244	Document	at		JPM	-SDNYLIT			-00724984	-00725000,	pro duced by
	JPMorgan	in	this	Action,		designated		Confidential	by JPMorgan	pursuan t to the
	Protective		Order	in this	matter	and fi	led	under	seal [Sealed]
Exhibit 245	Document	at		JPM		-SDNYLIT		-00448780,	pro duced	by JPMorgan in this
Action,			designated		Confidential	by		JPMorgan	pursuan t to	the Protective Order
in	this	matter	and	filed	under	seal	[Sealed]
Exhibit 246	Document	at		JPM		-SDNYLIT		-00016246	-00016256,	pro duced by
	JPMorgan	in	this	Action,		designated		Confidential	by JPMorgan	pursuan t to the
	Protective		Order	in this	matter	and fi	led	under	seal [Sealed]
Exhibit 247	Article by		Reuters,	J .P		to	Buy	Control	of Hedge	Fund, The New York
	Wt	ep t	28,	2004),	hops:	www	.ny	times	.com/2004/09/28/business/jp
		o	-buy	-control	-of-hedge	-fund		.html,	accessed July	20, 2023
Exhibit 248	Article,		Purchase	of	Highbridge		Capital		Management, J .P,	(June 11 ,
	https://web		.archive				.org/web/20120426055706/https://careers			.jpmorganchase .co
in/cm			Previously	marked	as	Staley	Exhibit	17	at deposition
Exhibit 249	Document		at	JPM		-SDNYLIT		-00004787	-00004789,	pro duced by
	JPMorgan		in this	Action,		designated		Confidential	by JPMorgan	pursuan t to the
	Protective		Order	in this	matter	and	filed	under	seal [Sealed]
Exhibit 250	August 8,		2006,	email,		JPM		-SDNYLIT	-00000254	-000002S5, pro duced
by	JPMorgan		in	this	Action,	and prev		iously	marked as	Exhibit 8 at
	deposition			JPMorgan	initially		designated	this	document	Confidential pursuan t
to	the	Protective		Order	in this	matter	but	has	withdrawn the	designation

Exhibit 251	Document	at		JPM		-SDNYLIT			-00026223	, pro		duced by	JPMorgan	in this
	Action,	and	prev	iously		marked	as	Third	-Party	Exhibit		109 at	the	deposition of
John		Duffy	Designated			Confidential		by	JPMorgan		pursuan	t to	the	Protective
	Order	in this	matter	and	fi	led	under	seal	[Sealed]
Exhibit 252	Excerpt	of	"JPMC		Cumulative			Privilege	Log"	(May	9,	2023),	pro	duced in
	Excel	format	by	JPMorgan		in	this	Action,		designated		Confidential	by	JPMorgan
	pursuan	t to	the Protect		Order	in	this	matter	and	filed		under seal	[Sealed]
Exhibit 253	Verified		Complaint,		Financial		Trust		Company,	Inc	v	The Bear	Stearns
	Companies		Inc, 3:09		-cv	-00106	-CVG	-GWB	(D	.V .I	Div	St		& St
	John,	Aug 5,	2009)
Exhibit 254 July	20,	2011	, email,			JPM		-SDNYLIT		-00274561		, pro	duced	by JPMorgan
in	this	Action,	and	prev		iously	marked	as	Cutler		Exhibit	21 at	deposition
	JPMorgan		initially		designated		this	document			Confidential		pursuan t	to the
	Protective		Order in	this		matter	but	has	withdrawn		the	designation		while
	retaining	its	original			redactions	to	the	document
Exhibit 255	July 22,	2011	, email,			JPM		-SDNYLIT		-00135958		R	-00135958	R,
pro		duced by	JPMorgan		in	this	Action,	and	prev	iously		marked	as	Cutler Exhibit
22	at	deposition			JPMorgan		initially		designated	this		document		Confidential
	pursuan	t to	the	Protective		Order	in	this	matter	but	has	withdrawn	the
Exhibit 256	Document	at			JPM			-SDNYLff-00269848,		pro		duced in	Excel	format by
	JPMorgan	in	this	Action,		and	prev	iously	marked	as		Langford	Exhibit	45 at
	deposition		JPMorgan			initially		designated	this		document		Confidential	pursuan t
to	the	Protective		Order	in	this	matter	but	has	withdrawn		the	designation	in par t
	and	the	document	is fi	led	under	seal	in	par t	[Sealed		in par t]
Exhibit 257	April	8, 2011	, email		and		attachment,		JPM		-SDNYLIT		-00230025
	00230028,		pro duced		by	JPMorgan		in this	Action,		and	prev	iously	marked as
	McCleerey		Exhibit	25	at	deposition			JPMorgan		initially		designated	this
	document		Confidential			pursuan	t to	the	Protective		Order	in this	matter	but has
	withdrawn		the	designation		in	par t	and the		document	is	filed	under	seal in par t
	[Sealed	in	par t]
Exhibit 258	July	22, 2011	, email,			JPM		-SDNYLIT		-00754982		-0075984,		pro duced by
	JPMorgan		in this		Action,	and	prev	iously	marked	as		Cutler	Exhibit	23 at
	deposition		JPMorgan			initially		designated	this		document		Confidential	pursuan t
to	the	Protective		Order	in	this	matter	but	has		withdrawn	the	designation	in par t
	and	the	document	is	filed	under		seal in	par t	[Sealed		in par t]

Exhibit 259	7/26/2011	, email,		JPM	-SDNYLIT		-00136106,	pro duced	by	JPMorgan	in
this	Action,	pro	duced	by	JPMorgan	in this	Action,	designated		Confidential	by
	JPMorgan	pursuan	t	to the	Protective	Order in	this matter	and fi	led	under	seal
Exhibit 260	March 29,	2011	, email,		JPM	-SDNYLIT	-00731610,	pro	duced	by
	JPMorgan	in	this	Action, and	prev	iously	marked as	Cutler Exhibit		30 at
	deposition		JPMorgan	initially		designated this	document		Confidential		pursuan t
to	the	Protective	Order	in	this matter	but has	withdrawn	the	designation
Exhibit 261	Document	at		JPM	-SDNYLIT	-00790948	R	-00790950_R,	pro		duced by
	JPMorgan	in	this	Action,	designated	Confidential	by	JPMorgan		pursuan	t to the
	Protective	Order	in	this matter	and fi	led under	seal	[Sealed]
Exhibit 262	Document	at		JPM	-SDNYLIT	-00892560	-00892561	, pro	duced	by
	JPMorgan	in	this	Action,	designated	Confidential	by	JPMorgan		pursuan	t to the
	Protective	Order	in	this matter	and	filed under	seal	[Sealed]
Exhibit 263	August	16, 2010,		email,	JPM	-SDNYLIT	-00752910		-000752912,
pro	duced	by	JPMorgan	in	this Action,	and	prev iously	marked	as	Cutler	Pachibit
20	at	deposition		JPMorgan	initially	designated	this	document		Confidential
	pursuan t	to the		Protective	Order in	this matter	but has	withdrawn		the
	designation		while	retaining	its original		redactions to	the document
Exhibit 264	February	6, 2011	,	email,		ESTATE	JPM -001591	, pro	duced	by	nonpar ty
The	Estate	of	Jeffrey	E	Epstein in	this Action	The	Estate	initially		designated
this		document		Confidential	pursuan	t to the	Protective	Order in	this	matter	but
has		withdrawn	the	designation
Exhibit 265	Document	at		JPM	-SDNYLIT	-00016652	-00016654,	pro	duced	by
	JPMorgan	in	this	Action	Designated	Confidential	by	JPMorgan		pursuan	t to the
	Protective	Order	in	this	matter and	filed under	seal	[Sealed]
Exhibit 266	Document	at		JPM	-SDNYLIT	-00016924,	pro	duced by		JPMorgan	in this
	Action,	designated		Confidential	by	JPMorgan	pursuan	t to the		Protective	Order
in	this	matter	and	filed under	seal	[Sealed]
Exhibit 267	Document	at		GF000664	-000670,	pro	duced by	nonpar ty	Bill	&	Melinda
	Gates	Foundation	in	this	Action,	designated	Confidential	pursuan	t	to	the
	Protective		Order in	this	matter and	filed under	seal	[Sealed]
Exhibit 268	Document	at		GV000028,	pro	duced by	nonpar	ty Gates	Ventures		in this
	Action,	designated		Confidential		pursuan t to	the	Protective	Order	in this	matter
	and filed	under	seal	[Sealed]

Exhibit 269	Document at=	JPM-SDNYLIT-00133931-00133932, produced by
Exhibit 270	Document ata	JPM-SDNYLIT-00005844, produced by JPMorgan in this
Exhibit 271	Document ata	JPM-SDNYLIT-00010121-00010122, produced by
Exhibit 272	December 12, 2008, email,` JPM-SDNYLIT-00099627, produced by
Exhibit 273	Full Transcript: CNN Anchor Poppy Harlow's exclusive interview with
Exhibit 274	Excerpt of Expert Report of Shaun O'Neill, CPA, CFF, CFE, dated May 16,
Exhibit 275	Due Diligence Report,	JPM-SDNYLIT-00149678-00149683, produced
Exhibit 276	March 1, 2011, email,	JPM-SDNYLIT-00100422-00100423, produced
Exhibit 277	Article by Constant Meheut, Epstein Associate Is Charged with Rape of Minors
Exhibit 278	Transcript excerpts of the Deposition of former U.S. Virgin Islands Attorney

Exhibit 279 2012		correspon	dence	between	Hodge	&	Francois	and	the	Office	of the	Attorney
	General	of	the V ,	* Islands	at =	VI	-JPM		-000012484		0000125491	This
is	an	excerp t	of=	VI -JPM		-000012328		-000012522,	pro	duced	by	Plaintiff
	Government		of the	United	States	Virgin	Islands	in	this Action,		and	prev iously
	marked	as	Frazer	Exhibit 18	at	deposition
Exhibit 280	Transcript		excerp ts	of the	30(6)(6)		Deposition	of U	.S Virgin		Islands
	Department		of	Justice	Sexual	Offender		Registry		Coordinator		Shani Pinney,
taken	on	July	18,	2023, in	this Action
Exhibit 281 2012		correspon	dence	between	Hodge	&	Francois	or	Darren	Indyke		and the
	Office	of the	Attorney	General	of	the	Virgin	Islands	at	VI	-JPM
	000012246		-000012250,	VI	-JPM	-000012263		-000012265,		and	VI	-JPM
	000012268		-000012272		These are	excerp	ts of		VI -JPM		-000012328
	000012522,		pro	duced by	Plaintiff		Government	of the	United		States	Virgin
	Islands	in	this Action,	and	prev iously		marked	as	Frazer	Exhibit	4 at	deposition
Exhibit 282	Transcript		excer at		Deposition	of	former	U .S	Virgin		Islands	Attorney
	General		Denise		taken on	July	17,	2023, in	this	Action
Exhibit 283	Transcript		excerp	ts of the	Deposition		of U .S	Virgin	Islands		Board	of
	Education		Interim	Executive		Director	and	former		Economic		Development
	Authority		Compliance		Officer U	.S	Sandra	Bess,	taken	on	May 17,	2023 , in
this		Action
Exhibit 284	Industrial		Development		Certificate	for	Financial		Trust	Company,	Inc	, March
22,	1999,		VI	-JPM	-000017992		-000018004,		pro duced	by	Plaintiff
	Government		of the	United	States	Virgin	Islands	in	this	Action,	and	prev iously
	marked	as	Bess	Exhibit 1	at deposition
Exhibit 285	Industrial		Development		Certificate		nsion)	for	Financial		Trust	Company,
Inc	.,	effective		January 1 ,	2012, =		VI -JPM		-000017983		-000017991	,
pro	duced	by	Plaintiff		Government	of	the	United	States	Virgin	Islands	in this
	Action,	and	prev	iously	marked as	Bess	Exhibit	2 at	deposition
Exhibit 286	Industrial		Development		Certificate	for	Financial		Trust	Company,	Inc	., October
25,	2012,		VI	-JPM	-000018005		-000018014,		pro duced	by	Plaintiff
	Government		of the	United	States	Virgin		Islands in	this	Action,	and	prev iously
	marked	as	Bess	Exhibit 3	at deposition
Exhibit 287	Transcript		excerp	ts of the	30(b)(6)		Deposition	of U	.S	Virgin	Islands
	Economic			Development	Authority		Managing		Director		Margarita
			taken	on May	26, 2023,	in	this	Action

Exhibit 288	Exhibit 1 at deposition.
Exhibit 289	Outline, "Jeffrey Epstein's EDC Companies,"M VI-JPM-000019063 —
	000019067, produced by Plaintiff Government of Sed States Virgin
	Islands in this Action, and previously marked as i Exhibit 12 at deposition.
Exhibit 290	Transcript of Public Hearing of the Economic Development Commission held
	November 15, 2012, VI-JPM-000016206-000016247, produced by
	previously marked ass Exhibit 19 at deposition.
Exhibit 291	Transcript excerpts of the Deposition of U.S. Virgin Islands Governor Albert Bryan, taken on June 6, 2023, in this Action.
Exhibit 292	Excerpt of transcript of Public Hearins of Economic Development
Exhibit 293	Letter dated January 7, 20L5 from Stephanie Berry to Jeffrey Epstein regarding
Exhibit 294	Letter dated January 8, 2014, from Erika Kellerhals to Stephanie Berry
	regarding Southern Trust Company, Inc., VI-JPM-000040186, produced
Exhibit 295	Transcript excerpts of Deposition of U.S. Virgin Islands Congresswoman and part.
Exhibit 296	Excerpt of transcript of Public H of the Economic Development

Exhibit 297	Transcript excerpts of <b>Deposition of former Financial Trust Company and Southern Trust Company Office Manager Cecile de Jongh</b> , taken on May 29, 2023, in this Action.
Exhibit 298	Transcript excerpts of the <b>30(b)(6) Deposition of U.S. Virgin Islands Economic Development Authority Managing Director Margarita [REDACTED]</b> , taken on July 14, 2023, in this Action.
Exhibit 299	Transcript excerpts of <b>Deposition of U.S. Virgin Islands Superior Court Judge and former Acting Attorney General Carol [REDACTED]</b> , taken on July 13, 2023, in this Action.
Exhibit 300	May 13-15, 2013, email thread regarding Quick response re: TOEFL, [REDACTED] <b>ESTATE_JPM024114-024118</b> , produced by nonparty The Estate of Jeffrey E. Epstein in this Action, and previously marked as C. de Jongh Exhibit 25 at deposition Designated Confidential pursuant to the Protective Order in this matter and filed under seal. <b>[Sealed]</b>
Exhibit 301	August 28, 2008, email, [REDACTED] <b>JPM-SDNYLIT-00003706_R</b> , produced by JPMorgan in this Action, and previously marked as [REDACTED] Exhibit 29 at deposition. JPMorgan initially designated this document Confidential pursuant to the Protective Order in this matter but has withdrawn the designation in part and the document is filed under seal in part. <b>[Sealed in part]</b>
Exhibit 302	July 10-11, 2011, emails and attachment, [REDACTED] <b>JPM-SDNYLIT-00110055-00110056 and JPM-SDNYLIT-00100548-00100549</b> , produced by JPMorgan in this Action, and previously marked as Third-Party Exhibit 85 at the July 12, 2023, deposition of Mary Erdoes. Designated Confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. <b>[Sealed]</b>
Exhibit 303	Photograph, previously marked as Third-Party Exhibit 85B at the July 12, 2023, deposition of Mary Erdoes. Designated Confidential pursuant to the Protective Order in this matter and filed under seal. <b>[Sealed]</b>

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct.¶

Dated: July 24, 2023¶

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UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK¶

DECLARATION OF MIMI LIU IN SUPPORT OF GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' MOTION FOR PARTIAL SUMMARY JUDGMENT¶

2. Attached hereto are true and correct copies of the following:¶