## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
GOVERNMENT OF THE UNITED ) STATES VIRGIN ISLANDS )
)
Plaintiff, )
v. ) Case Number: I :22-ev-10904-JSR
)
JPMORGAN CHASE BANK, N.A. )
)
DefendantiThird-Party Plaintiff. )
JPMORGAN CHASE BANK, N.A. )
)
Third-Party Plaintiff, )
)
v. )
)
JAMES EDWARD STALEY )
)
Third-Party Defendant. )
)
## DECLARATION OF MIMI LIU IN SUPPORT OF GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' MOTION FOR PARTIAL SUMMARY JUDGMENT
Pursuant to 28 U.S.C. § 1746, I, Mimi Liu, declare under penalty of perjury as follows:
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 |
| | 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 [REDACTED] LN_000001-000024 produced by a nonparty in this Action, designated Confidential pursuant to the Protective Order in this matter and filed under seal. [Sealed] |
| ---------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Exhibit 11 | Document at JDoe_DBAG_010034-010044 produced by a nonparty in this Action, designated Confidential pursuant to the Protective Order in this matter and filed under seal. [Sealed] |
| Exhibit 12 | Document at JDoe_DBAG_010023-010032 produced by a nonparty in this Action, designated Confidential pursuant to the Protective Order in this matter and filed under seal. [Sealed] |
| Exhibit 13 | Document at [REDACTED] JDoe_JPMC_007438-007448 produced by Plaintiff Doe in this Action, designated Confidential pursuant to the Protective Order in this matter and filed under seal. [Sealed] |
| Exhibit 14 | Document at [REDACTED] JDoe_JPMC_007449-007464 produced by Plaintiff Doe in this Action, designated Confidential pursuant to the Protective Order in this matter and filed under seal. [Sealed] |
| Exhibit 15 | Document at [REDACTED] LC 000456-000476 produced by a nonparty in this Action, designated Confidential pursuant 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 [REDACTED] In the Matter of the Estate of Jeffrey 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, 2008). |
| Exhibit 19 | Excerpt of Complaint, [REDACTED] v. Epstein , No. 10-cv-81111 (S.D. Fl. Sept. 17, 2010). |
| 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 [REDACTED] ESTATE_000454, ESTATE_000464, ESTATE_000466, ESTATE_000474, ESTATE_000500, ESTATE_000536 produced by nonparty The Estate of Jeffrey E. Epstein in this Action, designated Confidential pursuant to the Protective Order in this matter and filed under seal. [Sealed] |
| 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 | ILV | | 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 | Larry | 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 | 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 | -SDNYL1T | | -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(b)(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 | 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 | by | organ 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 | Erdoes | 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 fi | led 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 | | | .com/news/regionalnews/mysterf | | | mogu | ls_teen | | sex secret_b |
| | | ared | | in_probe_regionalnews | | | | 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, | | JPM | | -SDNYLIT | |
| | | 00174047 | | -00174061 , | dated | August | 5, | 2008, | pro | duced by | JPMorgan | | in this |
| | | Action, | and is | am 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] JPM-SDNYLIT-00137281 , produced by JPMorgan in this Action, and an article by Vicky [REDACTED], The Talented Mr. Epstein , Vanity Fair (March 1, 2003), https://www.vanityfair.com/news/2003/03/jeffrey-epstein-200303 (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] JPM-SDNYLIT-W-00025790 - 00025790_003 , 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] JPM-SDNYLIT-W-00025792 - 00025792_003 , 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 JPM-SDNYLIT-W-00025791 - 00025791_003 , 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] JPM-SDNYLIT-00151917-00151921 , 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] JPM-SDNYLIT-00174386-00174391 , 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] JPM-SDNYLIT-W-00037475-00037476 , 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 | |
| | 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 | ending 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, | 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 | | | -0015274tR, | 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/meeta | | -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, | | JPM | -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, | | | 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 | " 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 | | RM | -SDNYLIT | -W | -00021995 | | | -00021996, | pro | 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 | 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, | | = .11PM | | -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 | =JPM | | -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 | 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 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 | McCleary | | 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 | | -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 | | | .palmbeachpost | | | | .com/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 0 | 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 :Allibit 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 | | MIIJPM | | -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 | | -00157065y | |
| | 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 | Stearns | 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 | | -00037171 | | -00037177, | 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. [Sealed in part] |
| ----------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Exhibit 125 | Document at [REDACTED] JPM-SDNYLIT-00373074-00373076 , produced by JPMorgan in this Action, designated confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. [Sealed] |
| Exhibit 126 | Arthur Middlemiss LinkedIn Profile, https://www.linkedin.com/in/arthur-middlemiss-341a6b11/ . |
| Exhibit 127 | January 10, 2011, email, JPM-SDNYLIT-00157192-00157193 , 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] JPM-SDNYLIT-00373247 , produced by JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. [Sealed] |
| Exhibit 129 | Document at [REDACTED] JPM-SDNYLIT-00373248-00373252 , produced by JPMorgan in this Action, designated confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. [Sealed] |
| Exhibit 130 | Aug. 27, 2006, email, [REDACTED] JPM-SDNYLIT-00099337 , 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. [Sealed in part] |
| Exhibit 131 | Document at [REDACTED] JPM-SDNYLIT-00106627 , produced by JPMorgan in this Action, designated Confidential by JPMorgan pursuant to the Protective Order in this matter and filed under seal. [Sealed] |
| Exhibit 132 | Article, The Truth About Jeffrey Epstein and 'Vanity Fair' , posted by Chaire, http://www.gawker.com/302773/the-truth-about-jeffrey-epstein-and-vanity-fair , accessed June 27, 2023. |
| Exhibit 133 | May 28, 2008, email, [REDACTED] JPM-SDNYLIT-00134475 , 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. [Sealed in part] |
| Exhibit 134 | Article by John M. Cunningham, Miley Cyrus , http://www.britanica.com/biography/Miley-Cyrus , 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 | previously | | 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, | MIEJPM | | -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 | | JPM | -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 \* | | | | | |
| 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, | | kV | -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 | | -00130221 | -921 | .30226, | pro duced | by | | JPMorgan in | this Action, |
| and | prev | iously | | marked as | MI | 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 | -SDNYL1T | -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 fi | led | under | seal | [Sealed] | | | | |
| Exhibit 159 | Document | | at | JPM | -SDNYLIT | -W | -00000001 | | -00000002, | | JPM -SDNYLIT |
| | —W | -00000175 | | -000001132 | | (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 | -SDNYL1T | -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-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 | | -SDNYLff-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 | -SDNYL1T | | -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 filed | 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 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, | | JPM -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 | Other |
| 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 | -SDN'YLIT | | -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/mahinoud | | | -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] JPM-SDNYLIT-00006729 , 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] JPM-SDNYLIT-00101010-00101011 , 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] JPM-SDNYLIT-00022569 , 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] JPM-SDNYLIT-00393112 , 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] JPM-SDNYLIT-00028892-00028893 , 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] JPM-SDNYLIT-00029911-00029913 , 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] Apollo_VI_00000423 , 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] Apollo_VI_00000646 , 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] JPM-SDNYLIT-00013841 , 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] JPM-SDNYLIT-00014260 , 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 thc |
| 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(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_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 | Pxhibit |
| 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 | | .IPM | -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 | mattes |
| | and filed | under | seal | [Sealed] | | | | | | | |
| ti Exhibit 269 | Document an. JPM-SDNYLIT-00133931-00133932, produced by |
| -------------- | ---------------------------------------------------------------------------- |
| Exhibit 270 | Document ate JPM-SDNYLIT-00005844, produced by JPMorgan in this |
| Exhibit 271 | Document w 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 | Hoclg, | \_& | Francois | and | the | Office | of the | Attorney |
| ---------------- | ---------- | --------- | ------------ | -------------- | ------------- | ---------- | ----------- | ----------- | ----------- | --------- | ---------- | ----------- |
| | General | of | the V' | 1slands | 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 the States Virgin |
| | Islands in this Action, and previously marked a • L 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 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 |
| | Commission held February 12, 2009, a VI-JPM-000016200-000016205, |
| Exhibit 297 | Transcript excerpts of Deposition of former Financial Trust Company and Southern Trust Company Office Manager Cecile de Jongh , taken on May 29, 2023, in this Action. |
| ----------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Exhibit 298 | Transcript excerpts of the 30(b)(6) Deposition of U.S. Virgin Islands Economic Development Authority Managing Director Margarita [REDACTED] , taken on July 14, 2023, in this Action. |
| Exhibit 299 | Transcript excerpts of Deposition of U.S. Virgin Islands Superior Court Judge and former Acting Attorney General Carol [REDACTED] , taken on July 13, 2023, in this Action. |
| Exhibit 300 | May 13-15, 2013, email thread regarding Quick response re: TOEFL, [REDACTED] ESTATE_JPM024114-024118 , 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. [Sealed] |
| Exhibit 301 | August 28, 2008, email, [REDACTED] JPM-SDNYLIT-00003706_R , 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. [Sealed in part] |
| Exhibit 302 | July 10-11, 2011, emails and attachment, [REDACTED] JPM-SDNYLIT-00110055-00110056 and JPM-SDNYLIT-00100548-00100549 , 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. [Sealed] |
| 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. [Sealed] |
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct.
Dated: July 24, 2023
