EFTA00144344.pdf

MARSH LAW FIRM JENNIFER FREEMAN, ESQ New York, New York 10001 May 2, 2023 The Honorable Christopher Wray Director Federal Bureau of Investigation Michael E. Horowitz Inspector General U.S. Department of Justice Washington, D.C. 20535 Washington, D.C. 20530 The Honorable Merrick B. Garland Attorney General U.S. De artment of ustice NW Washington, D.C. 20530 Via Email and US. Mail Dear Director Wray, Inspector General Horowitz, and Attorney General Garland: As counsel to many survivors of the Jeffrey Epstein sex trafficking conspiracy, we write regarding the failure of the Federal Bureau of Investigation (FBI) to properly, adequately, or timely investigate the sex trafficking of hundreds of girls and young women. The FBI utterly failed to investigate serious allegations involving Epstein's, and perhaps others, child sex abuse materials (CSAM), significant additional criminality which, until recently, has been disregarded, disrespected, and essentially denied. As detailed below, in August of 1996 one of our clients, S reported to the FBI that Epstein and Ghislaine Maxwell had sexually abused her and that the two of them, together with others, were committing multiple, serious, sexual abuse crimes, including hands-on sexual abuse, against minors and 1 EFTA00144344 vulnerable young women. In addition, she reported to the FBI that Epstein, and perhaps others, appeared to be engaged in the production, possession, and distribution of sexually suggestive or exploitative images of children that could constitute CSAM. See Exhibits (Exs.) 1, 2, and 3. In 2005, child erotica was found in Epstein's Palm Beach home. In approximately 2008, law enforcement "prematurely" truncated their investigation of Epstein's computer hard drives which had been suspiciously removed from his Palm Beach estate immediately before a police raid. See infra p. 7. In 2019, more child erotica was found displayed in Epstein's properties, with additional images located in his home safe. See infra p. 9. Recently, for the first time. Epstein's possible connection to CSAM has been acknowledged - in ongoing federal litigation in New York, the Epstein Estate alerted the parties and the court about the possible existence of CSAM among images the Estate just discovered. Exs. 4 and 5. Last week, it was revealed that Epstein maintained government contacts at the highest level, including William Burns, director of the Central Intelligence Agency, who had three meetings scheduled with Epstein in 2014. Jeffrey Epstein's Private Calendar: CIA Director William Burns. Goldman Sachs's Top Lawyer. Noam Chomsky - WSl. As detailed below, in response to Ms. clear-eyed, prescient report, and despite subsequent repeated red flags that Epstein trafficked girls and collected sexualized images of children, the FBI appears, for years, to have done little to investigate and prosecute Epstein's sex trafficking, and, to date, done nothing regarding reports of possible CSAM. In order to ensure the fair and equitable dispensation of justice and accountability, we call on the FBI, the Department of Justice, and the Attorney General to conduct a comprehensive investigation to determine why there was and remains such abject failure to timely investigate, expose, and prosecute this unprecedented, decades-long criminal conspiracy which included not only the sexual trafficking of young women and girls, but also the possession and likely production, distribution, transportation and distribution of possible CSAM as well. 2 EFTA00144345 Law Enforcement Ignored Ms. 1996 Report to the FBI of Epstein's Possible CSAM Crimes and Sex Trafficking Conspiracy - Why? In 1995, Ms. a struggling artist and recent graduate from took a job working for billionaire Epstein. After purchasing one of her paintings for several thousand dollars, Epstein told Ms. that he wanted her to be an "art scour for his collection. This position expanded to clerical work in Epstein's mansion. Over the course of several months in 1996, Ms. witnessed young girls going in and out of Epstein's New York mansion, modeling agency representatives present at the house, and Ghislaine Maxwell "scouting" for new children who Epstein was purportedly also financially "helping:' Ms. also witnessed images of what appeared to be children in what was described to her as a "modeling book" kept in Epstein's safe. At first, Ms. accepted what sounded like innocent justifications for these activities. During the summer of 1996, at Epstein's behest, Ms. worked as an artist in residence at Epstein's home in Ohio. When Epstein and Maxwell visited Ms. in Ohio for a few days, they sexually abused her. Shocked and deeply shaken, she realized, when they left, that some photographs from her private collection, which were all numbered and in her possession in Ohio, were missing, including photographs of her partially dressed 11-year-old sister. She then became concerned that Epstein and Maxwell had other sexually inappropriate images, whether in Epstein's safe or elsewhere, and that they were engaged in other unlawful activities. Ms. leftend when she returned to New York, confronted Epstein and Maxwell and demanded the return of her personal photographs. Epstein and Maxwell retaliated against her by threatening to physically harm her and set all of her artwork on fire. Deathly afraid, on August 29, 1996, Ms. reported in detail Epstein's and Maxwell's criminality to her local police department, the NYPD The NYPD said that while they could address the local fire threats, they were unable to do anything about other possibly illegal activities 3 EFTA00144346 occurring outside their jurisdiction, such as the abuse and theft perpetrated in Ohio, and other illegal activities. They directed Ms. to report these alle ations to the FBI. See Ex. 1 (NYPD Police Report Complaint ated 8/29/96) - " I I states...[Epstein] did call her and state he was going to burn victim's painting and send her polaroids of the burnt paintings. [Epstein] has keys to victim's apartment:'). Following the NYPD's instructions, and at that time believing that the wrongdoing would be addressed, Ms. immediately contacted the FBI to report her wider criminal complaint concerning Epstein and others. Ms. confirmed her reporting of the Epstein conspiracy to the FBI in a 1997 entry in her personal journal: (lite Litt, • tisiontlegote ;11 1 S / &I t% ltivne`o Lat afr zseethi 7,5; ttl, al/ttna 1,141, 91A /116tiO i,i4L 4(2( erc j-wm Lfrtegn (.71 :to PS 1 , Ex. 2 (Journal title page and excerpt). *** Ms. 1996 report of the Epstein sex trafficking conspiracy and CSAM allegations was confirmed by the FBI in field notes of a 2006 meeting between Ms. and the agency, which was the first time she heard from the FBI after her original report. The FBI notes specifically stated that Ms. had previously reported Epstein to the NYPD Sixth Precinct who advised her to contact the FBI. 4 EFTA00144347 1 .e.cft(1 diglitta — Hr e..;&x... rigs-- • • • Excerpt of hand-marked page 19 of FBI redacted notes of 11/14/06 meeting with Ms. regarding Epstein ("6th precinct told MF to call FBI") in Ex. 3 (FBI redacted notes in full).1 The FBI agents acknowledged their awareness of Ms. 1996 report to the FBI about Epstein, stating that they tracked her down because of that earlier report. Ms. report of Epstein's sex trafficking and apparent CSAM crimes should have surprised no one who took the time to investigate. Indeed, it is commonplace for sexual abusers to use CSAM to normalize sexual conduct and groom victims. See, e.g., Understanding Grooming Tactics (rehope.org). Terrified and alone, and cognizant that the institutions that should have protected her failed to do so, Ms. moved out of New York City, and eventually out of the New York region, to escape Epstein's and Maxwell's abuse and threats. It Took a Decade for Federal Law Enforcement to Take Any Action Against Epstein Gifted Epstein the Deal of a Lifetime, and Conferred Free Reign on Epstein to Continue Sex Trafficking and Producing Sexually Suggestive Images of Girls and Young Women - Why? Ten years after Ms. initial report, federal authorities appeared to take a renewed interest in investigating Epstein which turned out to be nothing more than a paper tiger distraction. I Over the past several months, we have repeatedly sought unredacted co ies of the FBI's notes which presumably reveal more, and any prior notes from Ms. earlier report to the FBI. To date, no substantive response has been provided. EFTA00144348 From 2005 to 2008, dozens of survivors, including Ms. presented substantial evidence to the FBI of Epstein's sex trafficking and sexually inappropriate images of children. As noted above, on November 11, 2006, two FBI agents, without warning, knocked on the door of Ms. then-home in North Carolina and met with Ms. for hours. She again explained her deep, specific concerns about the ongoing Epstein sex trafficking conspiracy and CSAM allegations. See Ex. 3 (spanning over 20 pages of meeting notes). When the Palm Beach police raided Epstein's home in 2005, they found "naked pictures of teenage girls:' VIDEO: Inside Jeffrey Epstein's Palm Beach home: What the victims saw (palmbeachpost.com). At least one 14-year-old survivor told law enforcement that she had been photographed in the nude. See Report of the Department of Justice Office of Professional Responsibility (OPR Report). https://www.washingtonpost.comicontext/read-the-report- investigation-into-the-u-s-attorney-s-office-for-the-southern-district-of- florida-s-resolution-of-its-2006-2008-federal-criminal-investigation-of- jeffrey-epstein-and-its-interactions-with-victims-during-the- investigation/db9373e8-22f8-4712-b4a7-be844d162de0/, p. iv. As acknowledged in the OPR Report, law enforcement knew or had reason to believe that Epstein "had surveillance cameras stationed in and around his home" and "used hidden cameras in his New York residence to record his sexual encounters:' OPR Report, pp. 175-79. It was known that Epstein's "computers might have contained child pornography" and, with his "multi- state lifestyle[,] it was reasonable to assume that [there was possible] interstate transmission of child pornography...that could have changed the entire complexion of the case against Epsteinf OPR Report, p. 176. Six computer hard drives were suspiciously missing from Epstein's Florida home just before a police raid--leaving dangling wires attached to monitors-- which Epstein's attorneys refused to turn over. FBI Used Saw to Open Jeffrey Epstein Safe With Hard Drives Diamonds (insider:corn). Epstein's attorneys succeeded in delaying and then preventing the delivery of Epstein's hard 6 EFTA00144349 drives while law enforcement again turned a blind eye to allegations of possible CSAM crimes. See OPR Report, pp. iv, 45-47, 60-61, 70. As the OPR Report explained, the U.S. Attorney "resolved the federal investigation before significant investigative steps were taken," and the investigation ended "prematurely" OPR Report, p. x. Instead, Epstein and his team of high paid lawyers and private investigators sought to shift blame onto the victims, gaslighting them as prostitutes, drug addicts, and liars. Amazingly, despite a plethora of evidence of a far-reaching conspiracy to traffic women, and numerous red flags concerning possible CSAM, federal law enforcement stood by silently and didn't take action. OPR Report, pp. 11, 15, 147; see also https://www.palmbeachpost.com/story/news/2020/12/03/prosecutor- jeffrey-epsteins-victims-im-sorry-deal-labeled-you-prostitutes/3 812499001/ (AUSA told an appeals court that it was "unfortunate" that the non- prosecution agreement had the effect of "labeling teenage girls as prostitutes instead of victims of sexual assault"); FBI Records: The Vault — Jeffrey Epstein Part 17 of 22 (FBI file rife with what appear to be reams of victim "biographical information" and MySpace details). Meanwhile, consistent with well-known practices of sex traffickers, Epstein continued trafficking, raping, abusing, and collecting sexualized images of women and girls, including some of our clients. See OPR Report, p. 44. In 2008, the federal government agreed to a secret, controversial non- prosecution agreement (NPA) with Epstein which only required him to plead to rather minor state-law crimes and purportedly "immunized" his known and unknown co-conspirators. https://www.documentcloud.org/documents/6184602-Jeffrey-Epstein-non- prosecution-agreement. Epstein served only 13 months in a Palm Beach "country club" county jail with daily releases to his home-office. Nothing in the agreement obliged him to stop engaging in sex trafficking or any other illegal activity, and no consequences were imposed if he did. All the while he continued to disparage his minor victims. See NPA; OPR Report pp. ii, 70, 94- 110. That many of his victims were minors was ignored. 7 EFTA00144350 Our client, along with other survivors were trafficked at the very same time that the FBI was purportedly investigating Epstein. Although the Office of Professional Responsibility later examined actions of the Florida federal attorney-prosecutors during that time period, the actions of the FBI were not scrutinized. It is not known who in or about this time period had access to and removed Epstein's hard drives from his Palm Beach home, where else those hard drives might have been located, what those hard drives contained, and where those hard drives are today. The FBI Did Little or Nothing to Prosecute Epstein For an Additional Decade - Why? After the slap-on-the-wrist sentence, Epstein and others continued their criminal enterprise, while the FBI did little more for another decade. Further action against Epstein and his co-conspirators was taken only -- • after Ms. and other survivors complained again to law enforcement and engaged in substantial efforts working with non-FBI law enforcement; • after lengthy prosecution of federal civil litigation alleging the NPA violated the Crime Victims Rights Act guarantees and a federal court determination that the failure to notify victims and the NPA violated the Act; E.g., Doe v. United States, 359 F. Supp.3d 1201 (S.D. Fla. 2019); • after numerous journalists kept reporting the story; and • after numerous other private lawsuits and other efforts sought to bring this conspiracy to light and still do so. E.g., ane Doe v. Epstein, (2009) (579 F. Supp.3d (S.D.N.Y 2012)); v. Maxwell, Case No. 1-15-cv-07433-LAP (S.D.N.Y. complaint filed 2015); Jane Doe 1 v. Deutsche Bank et al., 22- cv-10018 (S.D.N.Y. 2022). It was not until approximately 2019 that the federal government finally prosecuted first Epstein and then Maxwell regarding the sex trafficking conspiracy. The FBI's repeated and continual failures, delays, and inaction 8 EFTA00144351 allowed Epstein and others to continue their sex trafficking conspiracy for nearly a quarter of a century. See OPR Report, pp. 27 n.38, 33, 44. Unfortunately, Ms. 1996 report regarding Epstein's sex trafficking and sexually concerning images proved to be spot on. In 2019 -- just as Ms. had reported to the FBI years decades earlier -- Epstein was charged with sex trafficking while sexually suggestive images of young girls were in fact found in a safe in Epstein's New York mansion. According to the SDNY prosecutors' memorandum seeking to deny Epstein bail, the 2019 search of Epstein's mansion unearthed a "'vast trove of lewd photographs' of young- looking girls, including hundreds of meticulously labeled nude pictures locked in a safe:" Jeffrey Epstein: Inside billionaire's New York mansion (usatoday.com). "CDs in the safe had hand-written labels, including 'Young [Name] + [Name]; 'Mist nudes 1, and 'Girl pies nude"' Feds found 'vast trove' of nude photos in Jeffrey Epstein's safe (nypost.com) See also Evidence from Jeffrey Epstein's safe 'went missing' after FBI raid. court hears in Ghislaine Maxwell trial (telegraph.co.uk): Ghislaine Maxwell trial: Photos of underage girls in Jeffrey Epstein's home entered as evidence (nbcnews.com). Had law enforcement taken even minimal action to respond to Ms. and others' 2006, 2008, 2011, and other reports, more sex trafficking and likely CSAM crimes could have been avoided. It is not known if at least some of the materials, such as the labeled nude photographs that were locked in Epstein's New York safe, were among those reported by Ms. in 1996. Law Enforcement Gave Epstein a Hall Pass for What Appears to Be One of the Largest and Longest Sex Trafficking and Alleged CSAM Conspiracies in our Lifetime - Why? Curiously, Epstein was known and tied to federal authorities for decades, often in connection with suspicious and illegal activities. In 1981, Epstein reportedly left Bear Stearns abruptly after committing a possible Regulation D violation with rumors of him engaging in other illegal activities. See The Talented Mr. Epstein - Vicky Ward. Epstein subsequently worked with Steven Hoffenberg at 9 EFTA00144352 Towers Financial who was prosecuted and imprisoned for bilking investors out of over $450 million in a Ponzi scheme that was then the largest financial fraud in American history. Hoffenberg, Epstein's business partner, went to jail but not Epstein. Instead of prosecution, in 1992, the U.S. State Department rented Epstein a luxurious townhouse in New York City that had been seized from the Iranian government. The State Department Once Rented A Townhouse Seized From Iran To Jeffrey Epstein — Then Sued Him For Subletting It (buzzfeednews.com) There has been rampant speculation for years that Epstein was a confidential informant. Only recently, a new "trove of papers" has revealed that "William Burns, director of the Central Intelligence Agency since 2021, had three meetings scheduled with Epstein in 2014 when he was deputy secretary of state..:' Jeffrey Epstein's Private Calendar: CIA Director William Burns, Goldman Sachs's Top Lawyer. Noam Chomsky - WSJ. Epstein told colleagues and friends that he was an intelligence asset. Andrew's Fixer: She's the Daughter of Robert Maxwell and She's Manipulating His Jetset Lifestyle funlimitedhangout.com), Epstein has been connected with many high-level government and business elites who accompanied him on multiple trips on the "Lolita Express" to the island of "Little St. Jeffs" and elsewhere but these individuals have not been the subject of scrutiny. The FBI closed a forfeiture proceeding against Epstein, noting "Epstein... has provided information to the FBI as agreed upon:' leffrey Epstein Part 06 of 08.pdf (last page). There is strong circumstantial evidence in the public domain that Epstein's special relationship with the government explains the FBI's failure to investigate or prosecute Epstein in 1996, the special treatment he received from 2005 to 2008, and the failure to investigate the possible wrongdoing of important public officials and powerful businessmen. The Epstein Estate Recently Alerted a Federal Court that CSAM May Exist in Recently Discovered Images and Videos Only weeks ago, for the first time, Epstein CSAM concerns have come under scrutiny, finally recognized by civil litigants otherwise facing possible prosecution themselves, as possible additional serious criminality by Epstein. 10 EFTA00144353 In a stipulated motion dated March 27, 2023, as part of a lawsuit brought by the Virgin Islands against JP MorganChase concerning the bank's financing of Epstein's activities, the parties advised the federal district court that the Epstein Estate had on March 14, 2023 discovered new videos and photographs (the Epstein Media). Government of the United States Virgin Islands v. JPMorgan Chase Bank N.A., Case No. 1:22:cv-10904-JSR, Stipulated Motion dated March 27, 2023, Ex. 4. The Epstein Estate expressly recognized the danger of serious criminal and civil liability attendant to possessing or distributing the Epstein Media which might contain CSAM. The Estate...advised counsel for the Government and Jane Doe1 of its concern that some of the Epstein Media might contain child sex abuse imagery ("CSAM"). The knowing accessing, possession, or distribution or CSAM is forbidden by federal law. See 18 U.S.C. §§ 2252, 2252A. The Estate has expressed concern that its counsel's review of the Epstein Media could subject counsel to criminal investigation or charges or civil claims.... Ex. 4 (footnote omitted). The parties prepared a stipulated motion to "[p]rovide the Epstein Estate with an approved protocol for reviewing the Epstein Media for purposes of this litigation only without fear or criminal or civil liability...and [p]rotect against disclosure or dissemination of CSAM..." Ex. 4. On April 5, 2023, the federal district court issued an Order establishing such a protocol, calling for the Estate to be on alert for CSAM. If, during the course of that review [of images], the Estate sees a particular recording that appears to contain possible CSAM, it shall promptly stop further review of that recording and notify the Federal Bureau of Investigation ("FBI") or such other agency or entity as the FBI may direct of the recording's existence. No CSAM shall be copied or transmitted to another party, except as directed by the FBI or other government. 11 EFTA00144354 Ex. 5. (Order April 5, 2023). It is telling that the Epstein Estate, the parties, and the Court believe it necessary to set up a CSAM protocol before Epstein media is reviewed. It is not known if at least some of the Epstein Media contains what Ms. reported in 1996. Much like the hard drives that went missing in Palm Beach or the nude photographs locked in Epstein's New York safe, it is not known who had access to the Epstein Media before the Court's Order, where else those materials might have been located, and what those materials contained. As to all three of these tranches of Epstein images, it is not known what the implications might be as to such access, possession, and location, by persons other than Epstein. See United States v. Russell, 639 F.Supp.2d 226 (D. Conn 2007) (attorney who took possession of laptop and destroyed hard drive containing CSAM indicted for obstruction of justice). The FBI Must be Held Accountable for Failures Regarding Epstein - just as Was Done Regarding the Parkland Shooting, Nassar Sex Abuse, and Charleston Shooting In 1996, federal law enforcement failed to investigate Ms. 1996 reporting of the Epstein sex conspiracy. There should be no question that Ms. who had never gone to law enforcement before, was credible and at least deserved a modicum of attention. In 2008, the FBI cut off their investigation "prematurely." To date, law enforcement still has not seriously pursued possible CSAM crimes involving Epstein. Had law enforcement done their job, the Epstein trafficking and possible CSAM crimes could have been stopped. Had law enforcement taken even minimal action to respond to repeated reports, many girls would never have been trafficked and the taking, distribution or transportation of sexually exploitative images would have been substantially reduced. The FBI's failure to seriously investigate Epstein and others is even more egregious than its documented failures in the investigation of the Parkland shooting, the Larry Nassar sex abuse of gymnasts, and the Charleston Church massacre. In the Parkland case, a federal investigation revealed that the FBI had received credible threats in the months before the shooting. See Summary 12 EFTA00144355 and Timeline Related to Parkland Shooting Investigation — FBI (House Judiciary Committee investigation). As the FBI explained regarding the Parkland shooting, "Under established protocols, the information provided by the caller should have been assessed as a potential threat to life. The information then should have been forwarded to the FBI Miami Field Office where appropriate investigative steps would have been taken7 FBI Statement on the Shooting in Parkland. Florida — FBI. As a result of the investigation of FBI failures, FBI employees were disciplined and Parkland victims were compensated. Justice Department to Pay About $130 Million to Parkland Shooting Victims - The New York Times (nytimes.com). In the Nassar case, a federal investigation found that two FBI agents in Indianapolis committed "fundamental errors" for not acting sooner on allegations of abuse. The Inspector General investigated and released a report concerning the FBI's failure to respond to the allegations of abuse "with the utmost seriousness and urgency that they deserved and required" and violations of FBI policy. DOI OIG Releases Report of Investigation and Review of the FBI's Handling of Allegations of Sexual Abuse by Former USA Gymnastics Physician Lawrence Gerard Nassar (justice.gov): Inspector General Says F.B.I. Botched Nassar Abuse Investigation - The New York Times {nytimes.com). In response to claims filed against the government, additional review of FBI failures is underway. As to the Charleston Church massacre, a federal investigation demonstrated that the FBI's lapses in background checks allowed the perpetrator, a self- proclaimed white supremacist who wanted to start a "race-war," to buy the semiautomatic weapon used in the shootings. In connection with the federal investigation, there have been changes in background check procedures, an appellate court ruled that the families of the survivors could seek redress from the federal government, and the government agreed to compensate the relatives of the deceased in order to "bring some modicum of justice to the victims of this heinous act of hate:' Justice Department Announces Multi- Million Dollar Civil Settlement in Principle in Mother Emanuel Charleston Church Mass Shooting I OPA I Department of Justice. 13 EFTA00144356 Much like the Parkland, Nassar, and Charleston Church cases, government agencies have a responsibility to investigate and explain why the FBI failed -- for a quarter of a century -- to properly investigate Ms. and others' repeated allegations of Epstein's abuse. Those failures allowed his sex trafficking to continue unabated for decades. It is imperative that the Epstein allegations similarly be accorded the "utmost seriousness and urgency that they deserved and required" and that the Epstein victims are also brought "some modicum of justice." Questions abound. What did the FBI do and not do to investigate Epstein? Why was absolutely nothing done in response to Ms. 1996 report of Epstein's and Maxwell's sex trafficking and CSAM concerns? Why were other repeated early complaints about Epstein to law enforcement ignored? Was law enforcement pressured to limit and truncate the Epstein investigation? Was law enforcement directed to cut Epstein loose to protect powerful public officials and businessmen who associated with Epstein or to protect Epstein's confidential informant status? Why did law enforcement give Epstein a pass on potential CSAM crimes by failing to obtain his computer equipment or by suspending investigation? Are any such images, perhaps produced by Epstein, currently traded and available on the internet? Why haven't the actions and inactions of the FBI regarding Epstein been investigated? Even the Florida Department of Law Enforcement investigated and reported on state law enforcement's handling of Epstein's wrongdoing (Investigative Summary: Work Release I PDF I Prison I Criminal Record (scribd.com), but not the federal government.) -- but to date federal law enforcement has utterly failed to do so. For many years, the public has been asking for a reckoning by the FBI and the United States government for its clear dereliction of duty to serve and protect the American people against the Epstein sex trafficking conspiracy. The FBI is said to hold itself to the highest of standards and integrity, grounding its initials in its motto of "Fidelity, Bravery and Integrity" and serving as the "lead agency for enforcing civil rights laws, aggressively investigat[ing] ... human trafficking and involuntary servitude...."https://www.fbi.gov/history/seal- motto; https://wwwfbi.gov/investigate/civil-rights. However, we are aware of 14 EFTA00144357 no investigation of the FBI and certainly no public disclosure or explanation. Epstein's and Maxwell's victims, and the public at large, are owed a full accounting of the FBI many failures and missed opportunities. The American people, the victims, and the survivors deserve the truth. We hereby request that a full and fair investigation be promptly launched into the FBI's seriously bungled examination and mismanagement of the crimes committed by Epstein and others. We look forward to your timely response. Sincerely, 15 EFTA00144358 EXHIBIT 1 EFTA00144359 ...f el"' Mew Ink City Police Department Omniform System - Complaints Rain., Crivel 004 Junsdietion: N.Y. ',etre DEPT ICAO*: Record Status: No Suns Complaint 9: 1516004007241 No Other Legacy Blue Versions No Other Complaint Revision* Occurrence Location: STREET Untie Or Premise. COMMERCIAL Premises Type. SUBBING Location ?Ann OFFICE AREA. Premise. Visible By Patrol?: NO NYC Parks Dept. Property Did max arena. occur on NYC Parks Dept Orefienr Command: NYC Parks Dept Property Name': "Thant 006 Sector: H Beat 11 Post: 32 Occurrence From: 1996-07-11 12:00:00 Occurrence MTh 1 t16-0/-17 00 Reported: 19•6-011-21 11-20 CallPlaiint Remmod: WALK-IN THURSDAY CO 03 01 Aided • Accident 0 0.C.C.B. • Classification: AGG HARRASSMENT Anempted/Completed. COMPT FEED Most Serious Offense NAI1 Is: POCon: 439 AGGRAVATEDHARASSMENT Pt Section: 24030 361 OF F. AGNST Keyooder a 2M 2 PUB CAD SENSBLEY Case Status: CLOSED Uret Referred To: PATROL Clearance Code. Log/Case v. 0 Clearance Arrest Id Clemente AO Cent File s: Prints Requested? NO Is Ilks Related To Stop And Frisk Report NO SOF Number. 0000.00000003 Was The Victim's Personal Information Taken Or Possessed? Was The Victim's Personal Information Used To Commit A Came? Gang Related? Detective Borough Wheel Log B Nome Of Gang: Chid Abuse Suspected? DIR Required? NO Child in Common? Intimate RidetIonship? Officer Body Went C • If Burglary: Alarm: If Arson: Taxi Robbery: Forced Entry? Structure: Entry Method: Entry Location. Bypatsed7 Comp Responded?: Company NunalPhone: Crim Prevention Survey NO Requested?. Compl Int/Roporter Present?: Structure Occupied? Damage ay Partition Present: Amber Stress Light Actreated. Method of Coma yanc• Location of Pickup. Supervisor On Scene - Rank / Nemo f Command Genres Conducted. Translate /0d used). NARRSTIOL WITNESS STATES. TAM) THE ABOVE MENTION 0 PERSON C40 CALL HER AND STATED HE WAS GOING TO BURN VICTIM'S PAINTING AND SEND HER POLOROIDS C4 THE BURNT PAIN RIGS. THE ABOVE MENTIONED PERSON HAS KEYS TO VICTIM'S APARTMENT. No NYC 'IRANSIT Data for Complaint # 1%96406-007241 Teal Their: I Teal Wearmen I Thal Raponen: 0 Tend %mud. I VICTIM: #1 of 1 laireS: 1996 Comp -006.407211 NNIVAKAAlidden: LIMOS: S.WType: FEMALE Rine: WHITE Age 21 Date Of Both: Disabled? NO Is Ins person not Proficient in English?: II Yes, Indicate Language: N.Y.C.MA Resident? b Victim nand for their safety IMO Escalating violence I abuse by suspect? Were prim DP's prepared for CAM GangiCriew Affinities Name. IdeMinees. WA View Photo: NO Will Prosecute: NO Notified Of Crime NO Victim Comp. Law: torAnott fronsPSS Mr STA/BOOlingRr ae /Tempe HOME-PERMANENT TREE? NYC NEW YORK 100140000 46 Phon• S. HOME Action against Victim Actions Of Victim Prior To Incident: Victim Of Similar boidenl If Yes. When And Wrong WITNESS : #1 of 1 inn 'Complaint a 1996-006-007241 morcuuvrianien: Sesfrype: FEMALE Ram' WHITE Age: 025 Date Of Bien Is this person not Proficient in Endlish?: NO Gang/Crete Infiliabon: NO Narne• Manners Relationship To Victim: EFTA00144360 M Mg Indicate Languages II I Location Addrim SlahsrolmbY I, ApOloom HOME•PERMANENT STREET MYC NEW YORK 100140000 30 Peen..: HOML eusmssIIIIMMIIIIIMI WANTED: #1 of 1 Nam: EPSTEIN. JEFFERY Complainte: 1996-006-007241 Amsted mcw44448444.4: WARM CET IN Sec MALE Wight - 204 Ram. %MEM Eye Crow. 14 Or Age: IS Hair Casa-. GRAY Date Of BIM: - - Hair Length SHORT U.S. Citizen: Has StM Place Of BMA Skm Tone Is this minion not ProMitint in English?: Complexion If V.. Indicate Language. Accent. Order Of Protection: binang Gime: Docket 0 Expiration Dale: Order of Protection Violated? Dom Suspect abuse Drugs I Alcohol? Suspect threatened /attempted suicide? Is the suspect Parole I Proestion? Relation to Mtn.. Living together. Can be Identified: Csansperms AMbatiorr Nanw. Identifiers: t OCATKIN le(I3LIESS CITY STATESCOVH1RY ap APT/ROOM HOW LONQ? RES, PCT HOME-PERMANENT -NYC NEW YORK 0 0 Phone • ALY.C.KA. Resident: N.Y.C. Hosting Employe* On OM- DevelOpment: N.Y.C. TIMM Employes: Physical Force: Used Emma System: Station Entered: Time Entered: Metro Card Type: Metro Card Med/Poem: Card O. CRIME DATA DETAILS CLOTHING ACCESSORIES - -UNKNOWN COLOR CLOYING FOOTWEAR • -UNKNOMI COLOR CLOTHING HEADGEAR • •UKNOAN CO-OR CLOTHING OJT ERMAR • •UNKNOtlets COLOR EVIDLNO2 'casino • I 996-006-007241 Pnikets Cdkorel; I !Mame (bilnine 2 gatnone Steer II.P.A.C, pet ItrepsoMil!: ECI Runs. Crime Mac Itnomike: Om, Sc.... timber. 146,14nte 144.4“ t No IMEI Data for Complaint # '996406.00724i Reportinginvestigating M.O.S. Name. PO CHANDLER, 00-0E Command: 006 PCT Rep.Aracy: NYPO pervisor Approving e epAgency: Supervisor ZI/LCH I Command: 006 PCT R NYPO Complaint Moon Entered By: PAA MARSALA, MARGAR I Commit 006 PCT RepAgency: HYPO Segnoff SOPerrisOr Name' 000000 Command: ReP.AgenCY: I.ND OF COMPLAINT REPORT * I oetidemterlt I Print this Repoli I EFTA00144361 EXHIBIT 2 EFTA00144362 - / 995" EFTA00144363 Th7 蓍）？少九l好;t241 nUn4gA 4'1 EFTA00144364 EXHIBIT 3 EFTA00144365 FEDERAL BUREAU OF INVESTIGATION POI/PA DELETED PAGE INFORMATION SHEET Civil Actionff 17-cv-03956 Total Deleted Page(s) = 283 Page 6 - b3 - 1; b6 - 3,-5; b7C - 3,-5; Page 10 - 43 - 1; 46 - 1,-3; 47c - 1,-3; Page 11 b3 - 1; b6 - 1,-3; b7C - 1,-3; Page 14 - b3 - 1; b6 - 3; b7C - 3; b7E - Page 15 b3 - 1; b6 - 3,-5; b7C - 3,-5; Page 16 - b3 - 1; b6 - 3,-5; b7C - 3,-5; Page 17 - b3 - 1; b6 - 3; b7C - 3; b7E - Page 18 - b3 - 1; b6 - 3,-5; b7C - 3,-5; Page 19 - - Page 20 - - Page 21 - - Page 22 - Page 48 - Page 49 - - Page 50 - - Page 51 - - Page 52 - Page 53 Page 54 - - Page 55 - - Page 56 Page 57 - Page 58 - - Page 59 - Page 60 - Page 61 - Page 66 - - Page 67 - - Page 68 - - Page 69 - - Page 70 - - Page 71 - - Page 72 - - Page 73 - - Page 74 - - Page 75 - - Page 76 - - Page 77 - - Page 81 - Page UZ - - Page 83 - Page 84 - Page 85 - Page 86 - Page 87 - Page 88 - Page 89 - Page 90 - b3 b3 b3 b3 b3 b6 b6 b6 b6 b6 b6 b6 b6 b6 b3 b3 b6 b6 b3 b3 b3 b3 b3 b3 b3 b3 b3 b3 b3 b3 b3 Di b3 b3 b3 b3 b3 b3 b3 b3 1; b6 - 3,-5; b7C - 3,-5; 1; b6 - 3,-5; b7C - 3,-5; 1; b6 - 3,-5; b7C - 3,-5; 1; b6 - 3,-5; b7C - 3,-5; 1; b6 - 3; b7C - 3; 5; b7C - 5; b7E - 1; 5; b7C - 5; b7E - 1; 5; b7C - 5; b7E - 1; 5; b7C - 5; b7E - 1; 5; b7C - 5; b72 - 1; 5; b7C - 5; b7E - 1; 5; b7C - 5; b7E - 1; 5; b7C - 5; b7E - 1; 5; b7C - 5; b7E - 1; 1; b6 - 3,-5; b7C - 3,-5; b7E - 1; - 1; b6 - 3,-5; b7C - 3,-5; b7E - 1; 5; b7C - 5; b7E - 1; 5; b7C - 5; b7E - 1; 1; b6 - 3; b7C - 3; b7E - 1; 1; b6 1; b6 1; b6 1; b6 1; b6 1; b6 1; b6 1; b6 1; b6 1; b6 1; b6 1; b6 1; bb 1; b6 - 1; b6 - 1; b6 1; b6 1: b6 - 1; b6 - 1; b6 - 1; b6 1; b7E - 1; b7E - 1; 1; b7E - 1; b7E - 1; b7E - 1; b7E - 1; b7E - 1; 2,-3; 2,-3; 3; b7C b7C - 2,-3; b7E b7C - 2,-3; b7E - 3; b7E - 1; 1; 1; 3,-5; b7C - 3,-5; b7E 1; 3,-5; b7C 3,-5; b7E 1; 3,-5; b7C 3,-5; b7E 1; 3,-5; b7C 3,-5; b7E 1; 3,-5; b7C 3,-5; b7E 1; 3,-5; b7C 3,-5; b7E 1; 3,-S; b7C 3,-5/ b7E 1; 3; b7C - 3; b7E - 1; 3; b7C - 3; b7E - 1; 0/c - s; D1b — 1; 3,-5; b7C - 3,-5; b7E - 1; - 3,-5; b7C 3,-5; b7E - 1; - 3,-5; b7C 3,-5; b7E - 1; 3,-5; b7C 3,-5; b7E - 1; 3,-5: b7C 3,-5: b7E - 1: - 3,-5; b7C 3,-5; b7E - 1; - 3,-5; b7C 3,-5; b7E - 1; - 3; 07C - 3; 47E - 1; EFTA00144366 FD-340 (Rev. 4-11-03) File Number 31 G- - -(14 --J otz - 0(02 ---(kiem-7 Field Office Acquiring Evidence nA. fr._ I CDRU.2 A-- Serial # of Originating Document Date Received Oa\ c)LA-• From (Name of Contributor/Interviewee) (Address) By C A (Ciry and 1 b6 -2 b7C To Be Returned Receipt Given 0 Yes 0 Yes 12'C B-C Grand Jury Material - Disseminate Only Pursuant to Rule 6 (e) Federal Rules of Criminal Procedure 0 Yes cleits1C— Federal Taxpayer Information (FTO El Yes Title: Reference: (Communication Enclosing Material) Description: G- --Cricinal notes re interview of 6-en ro, nkt‘i 1,6 -3 b7C 03956-8880 EFTA00144367 wry% arawywywaiii ragrFPIPTIIVW 1.6 -1,-3, -5 I 3 pfe _ -3-ras1413-) k‘s Arcs 4 0." .-Laark_ b6 -1,-3,-5 - b7C -1,-3,-5 b3 -1 • 039 4 5 h 6901 EFTA00144368 PTIIITITTVETP, ZWIWIFIFIWO 03%6-8902 So 301 _ rl EFTA00144369 psi saw 6_3) • -O.- • • •-• • -( 1-- - - - b67 -1.-3 /'b7C LitiS408.-b3 -17 03956'8903- - - EFTA00144370 Ps • • s enwinprimprrniqPIPOIlppre. _LE m_0- .1-4 b6 -1,-3,- b7C -1,-3,-5 /1-4a - w te-e_ aceio k;- 03956-8904 EFTA00144371 ? fir- - --loci Loy. str,d tc3—: LI tea Sep ce.e 69051 EFTA00144372 03956-8906 | EFTA00144373 _(41 eitnALIt-_ ',pad-41 ck. 14111 (j1"7r 4.5:c ClieJ s -L_ cces;-<, 61056-8907 EFTA00144374 eietilensiiian an ose my Ck seiof betel | vee ou ar EFTA00144375 glignIrrMirrThe Lip MN cr) .6ait 1,:‘A Lana t&-ut b3 1 -c, 3956-890 "3, EFTA00144376 r ib ‘ 15-FTWITTrPrPOWPrb WWI" l fn b6 -3! b7C -3 b3 -1 b6 -1,-3,-5 b7C -1,-3,-5 b7E Lk e‘: b6 -1,-3,-5 b7C -1,-3,- b76 -1 56-8910 - • - EFTA00144377 (03956- aa | EFTA00144378 7 11 cuku < c,,I +) liszkuar 3.6 tt _Lc._oft EFTA00144379 fiiVtFSTf irisiivwrwtW IFFT b6 -3,-5 b7C -3,- t-V‘1 b3 -1 03956-8913 EFTA00144380 woe _ Aw. COAL bet ah _ po tno of 03956-8914 | EFTA00144381 priTrriFIFTIPIWW-oT EFTA00144382 n -rrruir r• rerrnamr, .1-71-51 Y.oO Ca" V Am s .b6 -1, -9. b7C -1,-3 Sen,5 b3 -1 CHS C%-chrii174ff . critsL Ca.sfyir 03956-8916 EFTA00144383 -61fidik kyr-, y kr 1,151A7I-tr-4— 19Y-e- to"-_ !RA ti-toCC-A-‘, "HA-44,7 y e_ EFTA00144384 (.3 e • c l rho JIA67,-, EFTA00144385 iFETTTIMTVIrrr rsPri 03956-8919 WcI 44,5..: 3 EFTA00144386 rive We WTI 66 -1,-3.-5• 67C -1,-3,-5 EFTA00144387 trwrirrrrrs TT IFTYTTITTTre ottsee catijt hkickdr3t9t5:t1 EFTA00144388 Ldimeirrrirrin rot We is • *sti ff- I b7C -1 EFTA00144389 "a • if Maria • lb a.. al . b6 -3,-5 b7C -3,- b3 -1 03956-8923 EFTA00144390 6 -2.-51 7C -2,- b b F7>c 110i -zos :Hot 21 so .z._ f 255— cfliss tr. rwat s :9C / /0 7 UAWAo OPAILIALAAN. r t 4._„ 5.Oo 11 03956-8938 /A ire^ MAf -/OtOgi - Mit ri 'A EFTA00144391 EXHIBIT 4 EFTA00144392 igaM# 1:42--0,1469044§P 006tiffiefii 14t) Filed @4I /2§ Pa 9f UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED ) STATES VIRGIN ISLANDS ) ) Plaintiff, ) ) V. ) Case Number: I :22-cv-10904-JSR ) JPMORGAN CHASE BANK, N.A. ) ) Defendant/Third-Party Plaintiff. ) ) ) JPMORGAN CHASE BANK, N.A. ) ) Third-Party Plaintiff, ) ) V. ) ) JAMES EDWARD STALEY ) ) Third-Party Defendant. ) ) STIPULATED MOTION FOR APPROVAL OF PROTOCOL FOR REVIEW OF VIDEOMATERIALS AND PHOTOGRAPHS FOR THE PRESENCE OF POTENTIAL CHILD SEX ABUSE MATERIALS AND FOR DISCLOSURE OF THOSE MATERIALS Plaintiffs Jane Doe 1 and the Government of the United States Virgin Islands ("Government"), by their respective counsel, move pursuant to Federal Rules of Civil Procedure 26(c), and the authority of the Court to administer proceedings before it, for approval of an agreed- upon protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videorecorded materials and photographs in the possession, custody, or control of the Epstein Estate (the "Epstein Media") in response to subpoenas previously issued by Jane Doe 1 and, to the extent responsive to those subpoenas, disclose relevant portions of the Epstein Media EFTA00144393 Cm@ 02-ev:IONI4:3§R Postinwit HQ fag ®A/AA/2§ t3go 4 et (the "Responsive Media") to Jane Doe 1's counsel and to other parties in the litigations pending before the Court involving claims related to Jeffrey Epstein. Factual Background The Court is aware of the general nature of this case from earlier proceedings. For purposes of this Motion, it is relevant to note that Jane Doe 1 has alleged that she was the victim of coerced commercial sex trafficking by Jeffrey Epstein and his co-conspirators. Jane Doe 1 has issued a subpoena to the Epstein Estate, seeking certain videorecorded materials and photographs within the Epstein Media, and the Estate has agreed to produce Responsive Media in the Estate's possession to the extent that the production is not inconsistent with federal or state law, and to the extent that the videos or photographs were not downloaded or otherwise obtained at the time through publicly-available sources.' On March 14, 2023, counsel for the Epstein Estate notified counsel for Jane Doe 1 that it had located materials within the Epstein Media that may be responsive to her subpoenas. The Estate also advised counsel for the Government and Jane Doe 1 of its concern that some of the Epstein Media might contain child sex abuse imagery (CSAM2). The knowing accessing, possession, or distribution of CSAM is forbidden by federal law. See 18 U.S.C. §§ 2252, 2252A. The Estate has expressed concern that its counsel's review of the Epstein Media could subject counsel to criminal investigation or charges or civil claims in light of the possibility that the review ' Videos or photographs that were not obtained at the time through publicly-available sources is meant to include Responsive Media that may consist of movies or You Tube videos, for example, but does not extend to Responsive Media relating to Epstein activities or properties that may have been publicly disclosed at any time. 2 In this motion, the parties use the term "child sex abuse imagery" or CSAM as a synonym for the inappropriate term, "child pornography." See United States v. Larson, No. 5:19-CR-50165-RAL, 2023 WL 196171, at •1 (D.S.D. Jan. 17, 2023) ("Pornography connotes a certain aspect of consent that is impossible when the images or videos depict children."). EFTA00144394 Com 112e10004,J§R 006thil@fil 1 Filod 04/0g/25 Pe 5 of 5 of the Epstein Media could involve accessing CSAM. The Epstein Estate has advised that it does not have any specific knowledge that any of the Epstein Media does, in fact, contain CSAM, but wishes to put in place an appropriate procedure in case its counsel encounters such material. Proposed RCN leis Protocol Against that backdrop, counsel for the Government and Jane Doe 1 and the Epstein Estate have conferred and have agreed that the Government and Jane Doe 1 would move the Court for the entry of an order approving the following protocol for the Epstein Estate's review of the Epstein Media for potential production to parties in the litigations pending before the Court: 1. The Epstein Estate shall review the Epstein Media to determine its responsiveness to the subpoenas that have been issued by Jane Doe I and other parties to the related litigations. 2. If, during the course of that review, the Epstein Estate sees a particular recording that appears to contain possible CSAM, it shall promptly stop further review of that recording and notify the Federal Bureau of Investigation ("FBI") or such other agency or entity as the FBI may direct of the recording's existence. No CSAM shall be copied or transmitted to another party, except as directed by the FBI or other government agency. 3. If no CSAM is observed during the review, the Responsive Media will be provided to counsel for Jane Doe 1 and the Government in response to the relevant subpoena. To the extent Responsive Media is identified prior to the identification of possible CSAM, such materials also will be produced to counsel. Counsel for Jane Doe 1 and any other recipient of Responsive Media may then use this material for the prosecution or defense of the above-captioned case and make such further disclosures as are required by civil discovery rules (e.g., appropriate disclosures to opposing counsel). The attached proposed Order reflecting this protocol is intended to: EFTA00144395 (few P*-2--ey-4663644§P tztfeewati2 nki4 @x$Mig/g§ Pao 46* 1. Provide the Epstein Estate with an approved protocol for reviewing the Epstein Media for purposes of this litigation only without fear of criminal or civil liability; 2. Provide Jane Doe 1 with Responsive Media that may be relevant to her case; 3. Protect against disclosure or dissemination of CSAM; and 4. Follow the directive of 18 U.S.C. 3509(m) against reproduction of CSAM. Conclusion This Motion has been agreed to by the parties. Date: March 27, 2023 Respectfully submitted, /s/ Linda Singer Linda Singer (pro hac vice) Mimi Liu (pro hac vice) David I. Ackerman Paige Boggs (pro hac vice) MOTLEY RICE LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 Fax: (202) 232-5513 Isinger@motleyrice.com mliu®motleyrice.com dackerman@motleyrice.com pboggs@motleyrice.com Carol Thomas-Jacobs (pro hac vice) Acting Attorney General of the United States Virgin Islands Virgin Islands Department of Justice 34-38 Kronprindsens Gade St. Thomas, U.S. Virgin Islands 00802 Tel: (340) 774-5666 ext. 10101 carol.jacobs®doj.vi.gov Counsel for Plaintiff Government of the United States Virgin Islands /s/ Bradley Edwards Bradley J. Edwards EDWARDS POTTINGER LLP 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 brad@epllc.com Brittany N. Henderson EDWARDS POTT1NGER LLP 1501 Broadway, Floor 12 New York, NY Tel: (954) 524-2820 Fax: (954) 524-2822 brittany@eplic.com David Boies Andrew Villacastin BOLES SCHILLER FLEXNER LLP 55 Hudson Yards New York, NY Tel: (212) 446-2300 Fax: (212) 446-2350 dboies@bsfllp.com avillacastin@bsfllp.com EFTA00144396 EXHIBIT 5 EFTA00144397 Ozige11222c&v1D9g64JitiR PriallhitettitIPP21 1:41FicbCgog7g3 FPACielloCf72 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED ) STATES VIRGIN ISLANDS ) ) Plaintiff, ) ) V. ) ) JPMORGAN CHASE BANK, N.A. ) ) Defendant/Third-Party Plaintiff. ) ) ) JPMORGAN CHASE BANK, N.A. ) ) Third-Party Plaintiff, ) ) V. ) ) JAMES EDWARD STALEY ) ) Third-Party Defendant. ) ) Case Number: 1:22-cv-10904-JSR ORDER REGARDING REVIEW OF VIDEOMATERIALS Pursuant to Federal Rules of Civil Procedure 26(c) and the authority of this Court to administer its proceedings, and finding good cause established in the stipulated motion filed by Jane Doe I and the Government of the United States Virgin Islands, the Court orders that: 1. The Epstein Estate shall review the Epstein Media to determine its responsiveness to the subpoenas that have been issued by Jane Doe I and other parties to the related litigations. 2. If, during the course of that review, the Estate sees a particular recording that appears to contain possible CSAM, it shall promptly stop further review of that recording and notify the Federal Bureau of Investigation ("FBI") or such other agency or entity as the FBI may EFTA00144398 Celitt1142c671P9P314.W2 Q56611114itrAtiPP21 Fifddeb0Aigii§3 P%Cle23oPfi2 direct of the recording's existence. No CSAM shall be copied or transmitted to another party, except as directed by the FBI or other government agency. 3. If no CSAM is observed during the review, the Responsive Media will be provided counsel for Jane Doe I and the Government in response to the relevant subpoena. To the extent Responsive Media is identified prior to the identification of possible CSAM, such materials also will be produced to counsel. Counsel for Jane Doe I and any other recipient of Responsive Media may then use this material for the prosecution or defense of the above-captioned case and make such further disclosures as are required by civil discovery rules (e.g., appropriate disclosures to opposing counsel). SO ORDERED. JECatR eA.I' COFFiS Dated: March ti fr , 2023 New York, New York EFTA00144399 gam 1224friON44§14 Do@unimit OM§ Pap 5 915 Sigrid McCawley (pro hac vice) BOLES SCHILLER FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Fort Lauderdale, FL 33316 Tel: (954) 356-0011 Fax: (954) 356-0022 smccawley@bsfllp.com Counsel for Plaintiflane Doe 1 STIPULATED AND AGREED TO BY: /s/John Butts John Butts Felicia H. Ellsworth WILMER CUTLER PICKERING HALE AND DORR LLP 60 State Street Boston, MA 02109 Tel: (617) 526-6687 Fax: (617) 526-5000 john.butts@wilmerhale.com felicia.ellsworth@wilmerhale.com Counsel for Defendant JPMorgan Chase Bank, N.A. /s/ Zachary K Warren Zachary K. Warren (pro hac vice pending) WILLIAMS & CONNOLLY LLP 680 Maine Avenue SW Washington, DC 20024 Tel: (202) 434-5252 Fax: (202) 434-5029 zwarren@wc.com Counsel for Third-Party Defendant James Edward Staley EFTA00144400