Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/034-01.pdf

EXHIBIT 1 Case 1:22-cv-10904-JSR Document 34-1 Filed 01/26/23 Page 1 of 37 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED ) Case Number: 1:22-cv-10904-JSR STATES VIRGIN ISLANDS ) ) PLAINTIFF, ) ) V. ) LETTER OF REQUEST ) JPMORGAN CHASE BANK, N.A. ) ) DEFENDANT. ) PLAINTIFF’S LETTER OF REQUEST FOR DOCUMENT PRODUCTION IN THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND PURSUANT TO THE HAGUE CONVENTION OF 18 MARCH 1970 ON THE TAKING OF EVIDENCE ABROAD IN CIVIL OR COMMERCIAL MATTERS To the Central Authority of the United Kingdom of Great Britain and Northern Ireland: The UNITED STATES DISTRICT COURT for THE SOUTHERN DISTRICT OF NEW YORK, (the “Court”), presents its greetings and compliments to the Judicial Authority of United Kingdom of Great Britain and Northern Ireland (“UK”) and respectfully requests its assistance, through its competent judicial authority, in obtaining evidence in connection with a civil proceeding currently pending before this Court. This request is being made pursuant to Article 3 of the Hague Convention of 18 March 1970 on the Taking of Evidence in Civil and Commercial Matters, which is codified at 28 U.S.T. 2555. The Court asserts that the documents sought via this Request are directly relevant to the issues in dispute and are not discovery within the meaning of Article 23 of the Hague Evidence Convention; that is, merely testimony or documents intended to lead to relevant evidence for trial. Based on existing timetables, this Court has scheduled trial in this action for September 5, 2023. The deadline for obtaining evidence is currently set for April 24, 2023. The particulars of this Hague Evidence Request are as follows: Case 1:22-cv-10904-JSR Document 34-1 Filed 01/26/23 Page 2 of 37 1.Sender and Requesting Judicial Authority: Hon. Jed S. Rakoff UNITED STATES DISTRICT COURT Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 212-805-0401 2.Central Authority of the Requested State: The Legalisation Office THE FOREIGN & COMMONWEALTH OFFICE Norfolk House (West) 437 Silbury Boulevard Milton Keynes MK9 2AH UNITED KINGDOM Telephone: +44 (0)1908 295 111 3.a. The Person to whom the executed request is to be returned: Linda Singer (NYS Bar #2473403) MOTLEY RICE LLC 401 9 th Street NW, Suite 630 Washington, DC 20004 Telephone: (202) 232-5504 lsinger@motleyrice.com on behalf of: Hon. Jed S. Rakoff UNITED STATES DISTRICT COURT Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 212-805-0401 Case 1:22-cv-10904-JSR Document 34-1 Filed 01/26/23 Page 3 of 37 b. If there is urgency in having this letter executed, explain the reason here. This case is on an expedited trial schedule. All discovery, including depositions, must be completed by April 24, 2023. 4.Names and addresses of all parties and their representatives (including representatives in the UK): a.Plaintiff: Government of the United States Virgin Islands Virgin Islands Department of Justice 34-38 Kronprindsens Gade St. Thomas, U.S. Virgin Island 00802 Representatives: Carol Thomas-Jacobs Acting Attorney General Virgin Islands Department of Justice Office of the Attorney General 34-38 Kronprindsens Gade St. Thomas, U.S. Virgin Island 00802 Tel: (340) 774-5666 ex 10101 carol.jacobs@doj.vi.gov Linda Singer Motley Rice LLC 401 9th street, NW Suite 630 Washington, DC 20004 Tel: (202) 386-9626 lsinger@motleyrice.com David Ackerman Motley Rice LLC 401 9th street, NW Suite 630 Washington, DC 20004 Tel: (202) 849-4962 dackerman@motleyrice.com William H. Narwold Motley Rice LLC One Corporate Center 20 Church Street, 17 th Floor Hartford, CT 06103 Tel: (860) 882-1676 bnarwold@motleyrice.com Case 1:22-cv-10904-JSR Document 34-1 Filed 01/26/23 Page 4 of 37 Elizabeth Paige Boggs Motley Rice LLC 401 9th street, NW Suite 630 Washington, DC 20004 Tel: (202) 386-9629 pboggs@motleyrice.com b.Defendant: JP Morgan Chase Bank, N.A. 270 Park Avenue New York, New York 10017 Tel: (212) 270-6000 Representatives: Boyd Milo Johnson, III Wilmer Cutler Pickering Hale and Dorr LLP 7 World Trade Center 250 Greenwich St. New York, NY 10007 Tel: (212) 230-8800 boyd.johnson@wilmerhale.com Felicia H. Ellsworth Wilmer Cutler Pickering Hale and Dorr LLP 60 State Street Boston, MA 02109 Tel: (617) 526-6000 felicia.ellsworth@wilmerhale.com Robert Lee Boone Wilmer Cutler Pickering Hale and Dorr LLP 7 World Trade Center New York, NY 10007 Tel: (212) 295-6314 robert.boone@wilmerhale.com Ronald Machen Wilmer Cutler Pickering Hale and Dorr LLP 1875 Pennsylvania Avenue NW Washington, DC 20006 Tel: (202) 663-6881 ronald.machen@wilmerhale.com John Butts Wilmer Cutler Pickering Hale and Dorr LLP 60 State Street Case 1:22-cv-10904-JSR Document 34-1 Filed 01/26/23 Page 5 of 37 Boston, MA 02109 Tel: (617) 526-6515 john.butts@wilmerhale.com Hillary Chutter-Ames Wilmer Cutler Pickering Hale and Dorr LLP 7 World Trade Center 250 Greenwich St. New York, NY 10007 Tel: (212) 230-8848 hillary.chutter-ames@wilmerhale.com 5.Nature and Purpose of the Proceeding: The Government of the United States Virgin Islands (“Government”) brought this civil action against JPMorgan Chase Bank, N.A. (“JPMorgan”) as part of its ongoing effort to protect public safety and to hold accountable those who facilitated or participated in, directly or indirectly, the trafficking enterprise Jeffrey Epstein (“Epstein”) helmed. The Government’s investigation revealed that JPMorgan knowingly, negligently, and unlawfully provided and pulled the levers through which recruiters and victims were paid and was indispensable to the operation and concealment of the Epstein trafficking enterprise. Financial institutions can connect—or choke— human trafficking networks, and enforcement actions filed and injunctive relief obtained by attorneys general are essential to ensure that enterprises like Epstein’s cannot flourish in the future. Former JPMorgan senior executive Jes Staley (“Staley”) developed a close relationship with Epstein when Staley was the head of JPMorgan’s Private Bank. Between 2008 and 2012, Staley exchanged approximately 1,200 emails with Epstein from his JPMorgan email account. These communications show a close personal relationship between the two men, and that Staley nonetheless played a role in JPMorgan’s compliance decisions with respect to Epstein. They also reveal that Staley corresponded with Epstein while Epstein was incarcerated and visited Epstein’s Virgin Islands residence on multiple occasions. Staley left JPMorgan in 2013 and became the Chief Executive Officer of Barclays Bank PLC in 2015 until he resigned in November 2021 after the Financial Conduct Authority began a preliminary investigation into Staley’s relationship with Epstein. It has been publicly reported that Barclays Bank PLC produced documents to the Financial Conduct Authority as part of its investigation into Staley’s relationship with Epstein. These documents are equally applicable to the Government’s case. Case 1:22-cv-10904-JSR Document 34-1 Filed 01/26/23 Page 6 of 37 6.Evidence to be obtained or other judicial action to be performed: I.Request for Documents – The evidence to be obtained consists of various documents, listed on the attached Schedule A, which are maintained by the Witness Barclays Bank PLC [1 Churchill Place, London E14 5HP, United Kingdom], which employed a former senior executive at JPMorgan with a close relationship to Epstein. It is known that the Witnes