EFTA00162121

Oafletl.12204100204ISSR Cl0oornfiati86111 Fifddc00M3/330733 Plaggell6 of 123 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 75 of 76 
F. 
Pursuant to 14 V.I.C. § 607(a)(1), require Defendants to divest themselves of any 
real property or other interests in favor of the Government of the Virgin Islands used to further 
the goals of the Epstein Enterprise; 
G. 
Pursuant to 14 V.I.C. § 607(a)(3) and (5), order the dissolution of the Epstein 
Enterprise, including but not limited to, order the dissolution of the corporate Defendants; 
H. 
Pursuant to 14 V.I.C. § 607(a)(2) enter an injunction to prevent the further 
criminal conduct, and concealment of the criminal conduct, by the Epstein Enterprise; 
I. 
Pursuant to 14 V.I.C. § 607(a)(4), order the revocation of any and all licenses, 
permits and approvals that had been granted by any agency of the Territory, and require the 
repayment of any tax benefits that had been bestowed on any Defendant; 
J. 
Pursuant to 14 V.I.C. §§ 607(a)(6) and 607(k), order all assets and funds of the 
Estate of Jeffrey E. Epstein be placed into receivership; 
K. 
Pursuant to 14 V.I.C. § 607(e), award the Government the maximum civil 
penalty for each and every violation of law committed by the Epstein Enterprise; 
L. 
Pursuant to 14 V.I.C. § 607, award treble damages and all other available 
remedies, including attorneys' fees and costs; 
M. 
Award compensatory and punitive damages for Defendants' civil conspiracy; 
N. 
Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; 
O. 
Award such equitable relief, including disgorgement of all ill-gotten gains, as may 
be just and proper and appropriate, pursuant to 14 V.I.C. § 608(c)(4), to protect the rights of 
victims and innocent persons in the interest of justice and consistent with the purposes of CICO; 
P. 
Assess and award a judgment in favor of the Government and against the 
Defendants for attorneys' fees and costs and pre- and post-judgment interest; and 
EFTA00162361

081flt34122
1002041SSIR Moutmsett816611 FREKID0M3/310:123 Plagge312 of 123 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 76 of 76 
Q. 
Award any and all other relief this Court deems appropriate. 
The Government demands a jury trial on all issues so triable. 
RESPECTFULLY SUBMITTED, 
DENISE N. GEORGE, ESQ. 
ATTORNEY GENERAL 
Dated: February 10.2021 
/s/ Carol Thomas-Jacobs 
CAROL THOMAS-JACOBS, ESQ. 
Assistant Attorney General 
Virgin Islands Department of Justice 
Office of the Attorney General 
34-38 Kronprindsens Gade 
St. Thomas, U.S. Virgin Islands 00802 
Email: ariel.smith@doj.vi.gov 
(340) 774-5666 ext. 10101 
EFTA00162362

CaisteatjakettD:19BOSEERIDdacroanleiteLES211114thaaW3E12223 Fla2 
3 
UNITED STATES DISTRICT COURT FOR THE 
SOUTHERN DISTRICT OF NEW YORK 
GOVERNMENT OF THE UNITED 
STATES VIRGIN ISLANDS 
PLAINTIFF, 
V. 
JP MORGAN CHASE BANK, N.A. 
DEFENDANT. 
Case Number: OAP\ C 
ACTION FOR DAMAGES 
JURY TRIAL DEMANDED 
PROTECTIVE ORDER 
C)C\ 09 
The parties having agreed to the following terms of confidentiality, and the Court having 
found that good cause exists for issuance of an appropriately tailored confidentiality order 
governing the pre-trial phase of this action, it is therefore hereby 
ORDERED that any person subject to this Order -- including without limitation the parties 
to this action, their representatives, agents, experts and consultants, all third parties providing 
discovery in this action, and all other interested persons with actual or constructive notice of this 
Order -- shall adhere to the following terms, upon pain of contempt: 
1. 
Any person subject to this Order who receives from any other person any 
"Discovery Material" 
information of any kind provided in the course of discovery 
in this action) that is designated as "Confidential" pursuant to the terms of this Order 
shall not disclose such Confidential Discovery Material to anyone else except as 
expressly permitted hereunder. 
2. 
The person producing any given Discovery Material may designate as 
Confidential only such portion of such material as consists of: 
a. 
previously nondisclosed financial information (including without 
EFTA00162363

Castial222etelIOSOGIERIDdifibouenleiteLES2FIRMICCEW302423RitigNalittil23 
limitation profitability reports or estimates, percentage fees, 
design fees, royalty rates, minimum guarantee payments, sales 
reports and sale margins); 
b. 
previously 
nondisclosed 
confidential 
reporting 
to 
law 
enforcement agencies; 
c. 
previously nondisclosed material relating to ownership or control 
of any non-public company; 
d. 
previously nondisclosed business plans, product development 
information, or marketing plans; 
e. 
any information of a personal or intimate nature regarding any 
individual; 
f. 
any information maintained by JPMorgan Chase Bank, N.A. or 
its affiliates that is required to be kept confidential pursuant to the 
Bank Secrecy Act, 31 U.S.C. §§ 5311 to 5336, or its 
implementing regulations ("BSA") but for which the appropriate 
regulatory authority has authorized disclosure, including but not 
limited to the fact that no BSA information exists, (`BSA-
Protected Information")i and any information that, pursuant to 31 
U.S.C. 5318(g)(2)(A)(1), 31 C.F.R. § 1020.320, 12 C.F.R § 
21.11, Section 314(a) or (b) of the PATRIOT ACT, 12 U.S.C. 
§§ 3414(a)(3) and (c) or any other applicable regulations 
BSA-Protected Information maintained by other financial institutions are not within the scope 
of this Order and remain subject to the standard confidentiality requirements of the BSA and its 
implementing regulations. 
2 
EFTA00162364

Callastae/122SECtillEIBOSIMPDfiElcuaregitilLERRIFitrieD111021223 Regggabfd111123 
concerning 
potential 
suspicious 
activity 
("SAR-Related 
Information"), is not permitted to be produced unless authorized 
by the appropriate regulatory authority ("SAR-Protected 
Information"); 
g. 
any information that is confidential supervisory information 
("CSP") of the Board of Governors of the Federal Reserve System 
as set forth in 12 C.F.R. § 261.2(c), non-public information of the 
Office of the Comptroller of the Currency or the former Office of 
Thrift Supervision as set forth in 12 C.F.R. § 4.32(b), exempt 
information of the Federal Deposit Insurance Corporation as set 
forth in 12 C.F.R. §§ 309.2, 309.5, and 309.6, and confidential 
information of the Consumer Financial Protection Board as set 
forth in 12 C.F.R. § 1070.2, and any other records concerning 
supervision, regulation, and examination of banks, savings 
associations, their holding companies and affiliates, and records 
compiled in connection with the enforcement responsibilities of 
federal and state financial regulatory agencies that is not 
permitted to be disclosed to a third party absent consent of the 
applicable regulator or government agency unless authorized by 
the 
appropriate 
regulatory 
authority 
("CSI-Protected 
Information"); or 
h. 
any other category of information hereinafter given confidential 
status by the Court. 
3 
EFTA00162365

C alas fea.222.2etbalUILIGICSID thlhousitetialiS21111iMiECUIRCAB?3 FirSiggidgkilfealf112 3 
3. 
With respect to the Confidential portion of any Discovery Material other 
than deposition transcripts and exhibits, the producing person or that person's counsel 
may designate such portion as "Confidential" by stamping or otherwise clearly marking 
as "Confidential" the protected portion in a manner that will not interfere with legibility 
or audibility, and by also producing for future public use another copy of said Discovery 
Material with the confidential information redacted. For the avoidance of doubt, 
nothing herein is intended to prevent a party from designating the entirety of a given 
document as "Confidential" if the party reasonably believes the entire document falls 
within one or more of the categories in paragraph 2, above. With respect to deposition 
transcripts and exhibits, a producing person or that person's counsel may indicate on the 
record that a question calls for Confidential information, in which case the transcript of 
the designated testimony shall be bound in a separate volume and marked "Confidential 
Information Governed by Protective Order" by the reporter. 
4. 
If at any time prior to the trial of this action, a producing person realizes 
that some portion[s] of Discovery Material that that person previously produced without 
limitation should be designated as Confidential, he may so designate by so apprising all 
parties in writing, and such designated portion[s] of the Discovery Material will 
thereafter be treated as Confidential under the terms of this Order. If a party has 
disclosed such designated portion[s] of Discovery Material to anyone other than the 
individuals set forth in paragraph 5 below, that party shall make reasonable efforts to 
promptly retrieve such Discovery Material, and inform any recipient of the terms of the 
Order. 
5. 
With the exception of the qualifications pertaining to BSA-Protected 
4 
EFTA00162366

C 
tket1222€ etilTEIBOUERD difi1ousubeibiLli521111ikkM1113B8223 FfitiggaRpfdt1112 3 
Information, SAR-Protected Information and/or CSI-Protected Information in 
paragraph 6, no person subject to this Order other than the producing person shall 
disclose any of the Discovery Material, designated by the producing person as 
Confidential excluding any material containing BSA-Protected Information, SAR-
Protected Information and/or CSI-Protected Information to any other person 
whomsoever, except to: 
a. 
the parties to this action; 
b. 
counsel retained specifically for this action, including any 
paralegal, clerical and other assistant employed by such counsel 
and assigned to this matter; 
c. 
as to any document, its author, its addressee, and any other person 
indicated on the face of the document as having received a copy; 
d. 
any witness who counsel for a party in good faith believes may 
be called to testify at trial or deposition in this action, provided 
such person has first executed a Non-Disclosure Agreement in 
the form annexed as an Exhibit hereto; 
e. 
any person retained by a party to serve as an expert witness or 
otherwise provide specialized advice or services to counsel in 
connection with this action (including but not limited to 
professional jury or trial consultants, mock jurors, and persons or 
entities providing litigation support services — such as 
photocopying, videotaping, translating, preparing exhibits or 
demonstrations, and processing, hosting, organizing, storing, or 
5 
EFTA00162367

Catstealaketa091306133CFDdifilonareeiali52 RilitietC0113302033 RItiliffiggtheitE2 3 
retrieving data in any form or medium — and their employees and 
subcontractors), provided such person has first executed a Non-
Disclosure Agreement in the form annexed as an Exhibit hereto; 
f. 
any mediator or other dispute-resolution personnel, or any 
employee thereof, provided such person has first executed a Non-
Disclosure Agreement in the form annexed as Exhibit hereto; 
g. 
insurers, reinsurers, insurance adjusters, and/or third party 
administrators of insurance policies that do or may provide 
insurance coverage applicable to this action; 
h. 
stenographers engaged to transcribe depositions conducted in this 
action and videographers engaged to record depositions 
conducted in this action; and 
i. 
the Court and its support personnel. 
6. 
No person subject to this Order shall disclose any BSA-Protected 
Information, SAR-Protected Information, and/or CSI-Protected Information to any 
other person whomsoever, except to the following persons, consistent with any 
authorization received from the appropriate regulatory authority: 
a. 
the Government of the U.S. Virgin Islands and its counsel and 
JPMorgan Chase and its counsel, including any paralegal, clerical 
and other assistant employed by such counsel and assigned to this 
matter; 
b. 
any witness employed or formerly employed by JPMorgan Chase 
who counsel for the Government of the U.S. Virgin Islands or 
6 
EFTA00162368

C atilits&e21222eCtillESOGIEWfilacroaffaELBS2 FIRMS:C=1CM RItig3g477a610112 3 
JPMorgan Chase in good faith believes may be called to testify 
at trial or deposition in this action, provided such person has first 
executed a Non-Disclosure Agreement in the form annexed as an 
Exhibit hereto; 
c. 
any person retained by the Government of the U.S. Virgin Islands 
or JPMorgan Chase to serve as an expert witness or otherwise 
provide specialized advice to counsel in connection with this 
action, provided such person has first executed a Non-Disclosure 
Agreement in the form annexed as an Exhibit hereto; 
d. 
stenographers engaged to transcribe depositions conducted in this 
action and videographers engaged to record depositions 
conducted in this action provided such person has first executed 
a Non-Disclosure Agreement in the form annexed as Exhibit 
hereto; and 
e. 
the Court and its support personnel. 
7. 
Prior to any disclosure of any Confidential Discovery Material to any 
person referred to in subparagraphs 5(d), 5(e), or 5(f) above, such person shall be 
provided by counsel with a copy of this Protective Order and shall sign a Non-Disclosure 
Agreement in the form annexed as an Exhibit hereto stating that that person has read 
this Order and agrees to be bound by its terms. Said counsel shall retain each signed 
Non-Disclosure Agreement, hold it in escrow, and produce it to opposing counsel either 
prior to such person being permitted to testify (at deposition or trial) or at the conclusion 
of the case, whichever comes first. 
EFTA00162369

Castee2122260VECESOGEERDdifiYacerataliRilifittatIMIENZ23Rigialt23 
8. 
All Confidential Discovery Material filed with the Court, and all portions 
of pleadings, motions or other papers filed with the Court that disclose such Confidential 
Discovery Material, shall be filed under seal with the Clerk of the Court and kept under 
seal until further order of the Court. The parties will use their best efforts to minimize 
such sealing. In any event, any party filing a motion or any other papers with the Court 
under seal shall also publicly file a redacted copy of the same, via the Court's Electronic 
Case Filing system, that redacts only the Confidential Discovery Material itself, and not 
text that in no material way reveals the Confidential Discovery Material. 
9. 
Any party who either objects to any designation of confidentiality, or 
who, by contrast, requests still further limits on disclosure (such as "attorneys' eyes 
only" in extraordinary circumstances), may at any time prior to the trial of this action 
serve upon counsel for the designating person a written notice stating with particularity 
the grounds of the objection or request. If agreement cannot be reached promptly, 
counsel for all affected persons will convene a joint telephone call with the Court to 
obtain a ruling. 
10. 
All persons are hereby placed on notice that the Court is unlikely to seal 
or otherwise afford confidential treatment to any Discovery Material introduced in 
evidence at trial, even if such material has previously been sealed or designated as 
Confidential. The Court also retains unfettered discretion whether or not to afford 
confidential treatment to any Confidential Document or information contained in any 
Confidential Document submitted to the Court in connection with any motion, 
application, or proceeding that may result in an order and/or decision by the Court. 
11. 
Each person who has access to Discovery Material that has been 
8 
EFTA00162370

C anas&e2122eNIMBUGIERDtilikevartneiteLES2FIlildiattEW3E0223 Ra123 
designated as Confidential shall take all due precautions to prevent the unauthorized or 
inadvertent disclosure of such material. 
12. 
If, in connection with this litigation, a party inadvertently discloses 
information subject to a claim of attorney-client privilege or attorney work product 
protection, including any privilege or immunity from production associated with BSA, 
SAR-Related Information, and/or CSI ("Inadvertently Disclosed Information"), such 
disclosure shall not constitute or be deemed a waiver or forfeiture of any claim of 
privilege or work product or such other applicable protection with respect to the 
Inadvertently Disclosed Information and its subject matter. For avoidance of doubt, 
outside of authorization from an appropriate regulatory authority, the disclosure of BSA, 
SAR-Related Information and/or CSI shall not constitute or be deemed a waiver or 
forfeiture of any claim of privilege or work product or such other applicable protection 
with respect to such information. 
13. 
If a disclosing party makes a claim of inadvertent disclosure, the 
receiving party shall not thereafter review the Inadvertently Disclosed Information for 
any purpose, except by order of the Court. The receiving party shall, within five business 
days, return or destroy all copies of the Inadvertently Disclosed Information, and 
provide a certification of counsel that all such information has been returned or 
destroyed. 
14. 
Within five business days of the notification that such Inadvertently 
Disclosed Information has been returned or destroyed, the disclosing party shall produce 
a privilege log with respect to the Inadvertently Disclosed Information. 
15. 
As with any information redacted or withheld, the receiving party may 
9 
EFTA00162371

Oaaase22222eelAD992aSESRCEDeananitttGEE2 
PlIggaD2ceiLU3 
move the Court for an Order compelling production of the Inadvertently Disclosed 
Information. The motion shall be filed under seal, and shall not assert as a ground for 
entering such an Order the fact or circumstances of the inadvertent production. 
16. 
The disclosing party retains the burden of establishing the privileged or 
protected nature of any Inadvertently Disclosed Information. Nothing in this Order shall 
limit the right of any party to request an in camera review of the Inadvertently Disclosed 
Information. 
17. 
This Protective Order shall survive the termination of the litigation. 
Within 30 days of the final disposition of this action, all Discovery Material designated 
as "Confidential," and all copies thereof, shall be promptly returned to the producing 
person, or, upon permission of the producing person, destroyed. For the avoidance of 
doubt, counsel of record in this action shall be permitted to keep copies of filings and 
work product that incorporates any Confidential Discovery Material, so long as counsel 
continues to treat such Confidential Discovery Material in accordance with this Order. 
18. 
This Court shall retain jurisdiction over all persons subject to this Order 
to the extent necessary to enforce any obligations arising hereunder or to impose 
sanctions for any contempt thereof. 
SO STIPULATED AND AGREED. 
10 
EFTA00162372

O2taaa22222ettleD29214SERRCiThitarmanit+261I2 
Plagttelnothfl .113 
/s/ Linda Singer 
LINDA SINGER 
Admitted Pro Hac Vice 
Motley Rice LLC 
401 9th Street NW, Suite 630 
Washington, DC 20004 
Tel: (202) 232-5504 
Isinaer@motleyrice.com 
Dated: January 9, 2023 
SO ORDERED. 
Dated: New York, New York 
/— 
3
11 
/s/ Boyd Johnson 
WILMER CUTLER PICKERING 
HALE AND DORR LLP 
Boyd M. Johnson III 
Robert L. Boone 
Hillary Chutter-Ames 
7 World Trade Center 
250 Greenwich Street 
New York, NY 10007 
(t) (212) 230-8800 
(f) (212) 230-8888 
boycljolmson®wilmerhale.com 
robert.boone@wilmerhale.com 
hillary.chutter-ames®wilmerhale.com 
Felicia H. Ellsworth 
60 State Street 
Boston, MA 02109 
(t) (617) 526-6687 
(f) (617) 526-5000 
felicia.ellsworth@wilmerhale.com 
Dated: January 9, 2023 
JEDWAKOFF, .S.D.J. 
EFTA00162373