Draft: efta02811257

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-lawsuithtml.
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
	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-SDNYL1T-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		000001		-000024	pro	duced	by a	nonpar	ty	in	this	Action,
	designated	Co	ender	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	filed	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 filed	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 filed	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 filed	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
	Jeffrey	Epstein,	Superior		Court of	the	Virgin	Islands,		March	12,	2020
Exhibit 17	Creditor's	Claim	on behalf		of		In	the	Matter	of	the	Estate		ofJeffrey
	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	Complaint=f.		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,			ATE_000474,		ESTATE		000500,			ESTATE_0		00536
	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 filed	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 1	.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		-0004747(N		000491	-000492	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 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	ME	JPM	-SDNYLIT		-00128026	-00128033	pro	duced	by
	JPMorgan	in	Action,		and prev	iously	marked	as Pearn		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
		0003718340037205,	pro	duced	by	JPMorgan	in 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	,	MJPM
	SDNYLIT		-00013546,	JPM	-SDNYLIT		-00013551	, pro	duced	b3711	5 Ylorgan 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:	Tlial2tter,		Warrants		Were	Prepared to
	Arrest	Others	in	Millionaire		Sex	Scandal,		JPM		-SDNYLIT		-00269657
		00269658,	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					.coin/news/regionalnews/mystertmoguls_teen					sex_secret_b
	rued	in pro	be reg	ionalnews			angan	htm,	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,		JIPM		-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		Confidentia	.)
		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	fi	led 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
	SDNYL1T		-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	ending in	2810,		JPM	-SDNYL1T
	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,	MIJPM		-SDNYLIT			-00152804
00152806,		pro	duced	by	JPMorgan,	and	prev	iously	marked	as	Ryan	Exhibit 34
at	deposition		JPMorgan		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	JPMorgan		pursuan t to the
Protective		Order	in	this	matter and	filed	under	seal		[Sealed)
Exhibit 68 February	9,	2004,	Due		Diligence	Report,		MIIIPM		-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		-00152748	_R,	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	IMI 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	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
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 74 June	9, 2010,		email,	MIJPM		-SDNYLIT		-00008237		-00008240,	pro	duced by
JPMorgan	in	this		action, and	prev	iously	marked	as		eltExhibit	35	at
deposition			JPMorgan	initially		designated	this			documentConfidential		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,			MEJPM	-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	Jill	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		JPM	-SDNYLIT	-W	-00021995			-00021996,	pro	duced by
	JPMorgan	in	this	Action,	and prev	iously	marked	as		DeLuca	Exhibit	29 at
	deposition		Designated		Confidential		pursuan t	to the		Protective	Order	in this
matter	and fi	led	under	seal	[Sealed]
Exhibit 79 Currency			Transaction	Reports,		pro duced	by	third	-arty	the	Financial	Crimes
	Enforcement		Network		("FinCEN")	in	this	Action
Exhibit 80 July	16, 2008,		email	and	attachment,		=JPM		-SDNYLIT		-00269718
	00269719,	pro	duced	by	JPMorgan	in	MI	Action,		designated	Confidential
pursuan	t to	the		Protective	Order	in this	matter	and	filed	under	seal	[Sealed]
Exhibit 81	Document	at	=JPM		-SDNYLIT	-W	-00021932			-00021937,	pro	duced by
	JPMorgan	in	ffi	lAction,	and	prev	iously	marked as		McCleerey	Exhibit	13 at
	deposition		Designated		Confidential		pursuan	t to the		Protective	Order	in this
matter	and	fi	led under	seal		[Sealed]
Exhibit 82	Document	at		JPM	-SDNYLIT		-W	-00021965		-0021966,	pro	duced by
	JPMorgan	in	this	Action,	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 SUP includes tables summarizing relevant information from the currency transaction reports. The Government will provide these documents to the Court at its reques^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 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	pa d	[Sealed in
par	t]

Exhibit 91 July	26,,2006,	email,		NEJPM		-SD1NYLIT		-00099335			roduced	by JPMorgan
in this	Action,	and	Palm		Beach Post	article	by	Lany			After	long pro be,
Palm	Beach	billionaire		faces		solicitation	charge,	pu		blishedJuly		26, 2006, at
http://www					.palmbeachpostcom/pbccentrallcontent/local							new/epaper/2006/07/2
6/slb	EPSTEEN1	_0726		.html,	accessed	March		15,	2023	through
latlweb	.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		Order in	this	matter	but	has	withdrawn		the
designation	in	par t	and	the	documents	are	filed	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	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
Exhibit 97 July	15, 2008,	email		and	multiple	attachments,				JPM		-SDNYLIT
00003026		-00003035,		pro	duced	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	fi	led 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,			JPM	-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			-SDNYLff-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		TJPM		-SDNYLIT		-00751686,	pro	duced	by	JPMorgan	in this
Action,	designa			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://nypostcom/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,		i	JPM	-SDNYLIT
00194018		-00194021		, pro	duced	by	JPMorgan	in	s	ction, 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		-00157065R
	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	filed	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 par t
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 pa	d]
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	Protective		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				.com/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			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 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 .part	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
fi	led	under seal	in	par t	[Sealed in	par t]
Exhibit 145	December	5,	2009,	email	and	attachment,	MIERM	-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		SPM	-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	Acton,	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	*
Th rhibit 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	-SDNYLTT
	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,	IVW	-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	-000	17206	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 filed	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			-SDNYLff-0010aproduced		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		JPM	-SDNYLIT		-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	-SDNYLIT		-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,	entail,			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 fi	led	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 filed	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	[Sealed]
Exhibit 196 October		26,	2006,	email,		IPM -SDNYLIT	-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	Other
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	Other	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		LinkedIn		Profile,	available	at:
https://www		.linkedin	.com/in/malunoud			-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 fi	led	under	seal	[Sealed]

Exhibit 211 Document	at	JPM		-SDNYLIT	-00006729,	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 212 August	15, 2013	, email,			JPM -SDNYLIT	-00101010		-00101011		, pro duced
by JPMorgan	in	this	Action,	and	prev iously	marked	as Erdoes		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	filed	under	seal in par	t [Sealed	in par	t]
Exhibit 213 July	10, 2012,	email,		JPM	-SDNYLIT	-00022569,	pro	duced		by JPMorgan
in this	Action,	and prev	iously	marked	as	Erdoes Exhibit	31	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 214 Document	at	JPM		-SDNYLIT	-00393112,	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 215 Document	at	JPMSDNYLIT			-00028892	-00028893		, 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 216 Document	at	JPM		-SDNYLIT	-00029911	-00029913,		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 217 Document	at	Apollo		VI	00000423,	pro duced	by nonpar		ty Apollo	Global
Management		Inc in	this	Action,	designated	Confidential		pursuan	t	to the
Protective	Order	in this		matter	and filed	under seal	[Sealed]
Exhibit 218 Document	at		Apollo_VI		00000646,	pro duced	by nonpar		ty Apollo	Global
Management,		Inc in	this	Action,	designated	Confidential		pursuan	t	to the
Protective	Order	in	this	matter	and filed	under seal	[Sealed]
Exhibit 219 March	23 , 2011	, email,			JPM -SDNYLIT	-00013841		, pro	duced	by
JPMorgan	in	this Action,		and	prev iously	marked as	Staley	Exhibit		12 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 220 Document	at		JPM	-SDNYLIT	-00014260,	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 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	"Morgan		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(bX6)	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),	https:	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	-00000255, 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	-SDNYLIT		-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 filed	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_12,		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	Exhibit
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 a'	JPM-SDNYLIT-00133931-00133932, produced by
Exhibit 270	Document ate	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	HocJIgi&		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	excerp	ts	of	the	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			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," VI-JPM-000019063 —
	000019067, produced by Plaintiff Government of Sed States Virgin
	Islands in this Action, and previously marked a e.. 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 Hearin s of the 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¶

Keyboard shortcuts

Go to a page: `g` then

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:¶