EFTA00161836

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 67 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 66 of 76 
381. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of 
CICO. 14 V.I.C. §600 et seq. 
COUNT TWENTY-TWO 
Civil Conspiracy 
382. 
The Government restates and realleges paragraphs 1 to 381 of this Complaint as 
if fully set forth herein. 
383. 
Defendants acted in concert and joined with others to perform the wrongful acts 
identified in Counts 1 to 13, among others, concealing the sexual abuse of minor females by 
unlawful means. 
384. 
Each co-conspirator knew, or in the exercise of reasonable care should have 
known, about the conduct of the others and about the common unlawful scheme. 
385. 
These unlawful acts could not have been carried to the length and extent 
accomplished without the common understanding shared by Epstein and the Epstein Enterprise 
Defendants. 
386. 
Each of the Defendants had a duty to report, stop or terminate the wrongful 
conduct, but instead each Defendant concealed, assisted and furthered the wrongful acts by use 
of civil conspiracy. 
387. 
As a direct and proximate result of Defendants' conspiracy, the Virgin Island has 
been injured. 
388. 
Each co-conspirator is jointly and severally liable for the acts alleged herein. 
EFTA00161936

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 68 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 67 of 76 
COUNT TWENTY-THREE 
Fraudulent Claims Upon the Government—Southern Trust Company, Inc. 
Violation of the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. § 600 et seq. and 14 V.I.C. § 843 
389. 
The Government restates and realleges paragraphs I to 388 of this Complaint as 
if fully set forth herein. 
390. 
At all times relevant and material herein, each Defendant directly and indirectly 
participated in or associated with the Epstein Enterprise, an illicit enterprise. 
391. 
Each Defendant engaged in two or more occasions of conduct that constitute 
criminal predicate acts as defined by CICO, including, but not limited to, making fraudulent 
claims upon the Government. 
392. 
The Epstein Enterprise misrepresented the purpose, activities, employment, and 
income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax 
incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the 
Epstein Enterprise, with the active participation of Defendants Indyke and Kahn, used Southern 
Trust Company to employ, pay, and conceal the activities of participants in the criminal 
activities of the Enterprise. 
393. 
The Epstein Enterprise made and presented an application for tax incentives, 
testimony, and quarterly reports to the EDC, a commission of the Government, regarding the 
Southern Trust Company, knowing such claims to be false, fictitious, or fraudulent; knowingly 
and willfully falsified, concealed or covered up material facts regarding the Southern Trust 
Company; made false or fraudulent statements or representations about the purpose, activities, 
income, and employment of Southern Trust Company; and made and submitted false affidavits 
knowing the same to contain any fraudulent or fictitious statement or entry. 
EFTA00161937

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 69 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 68 of 76 
394. 
These false statements and documents included affidavits, testimony, an 
application, and other documents that misrepresented that Southern Trust Company was 
engaged in, and failed to disclose it did not and could not carry out, in its stated purpose of 
providing consulting services in financial and biomedical informatics. 
395. 
Defendants knowingly benefited financially and/or obtained other non-financial 
value from participation in the Epstein Enterprise, which has engaged in human trafficking, 
forced labor, sexual servitude, and commercial sexual activity of underage girls and young 
women in knowing and reckless disregard of the laws of the Virgin Islands. 
396. 
Defendants through a pattern of criminal activity acquired and maintained, 
directly or indirectly, an interest in or control of the Epstein Enterprise or real property. 
397. 
Defendants benefited, directly and indirectly, from the pattern of criminal 
activity conducted by the Epstein Enterprise. 
398. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of 
CICO. 14 V.I.C. § 600 et seq. 
COUNT TWENTY-FOUR 
Fraudulent Claims Upon the Government—Southern Trust Company, Inc. 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 
14 VI.C. § 600 et seq. and 14 V.I.C. § 843 
399. 
The Government restates and realleges paragraphs 1 to 398 of this Complaint as 
if fully set forth herein. 
400. 
At all times material herein, each Defendant joined in a conspiracy to commit 
fraudulent conveyances. 
EFTA00161938

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 70 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 69 of 76 
401. 
Each Defendant engaged in acts that revealed its intent to join and participate in 
the criminal conspiracy, including, but not limited to, transferring assets to and between various 
entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder or delay claims 
against them. 
402. 
The Epstein Enterprise misrepresented the purpose, activities, employment, and 
income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax 
incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epstein 
Enterprise, with the active participation of Defendants Indyke and Kahn, used Southern Trust 
Company to employ, pay, and conceal the activities of participants in the criminal activities of 
the Enterprise. 
403. 
The Epstein Enterprise made and presented an application for tax incentives, 
testimony, and quarterly reports to the EDC, a commission of the Government, regarding the 
Southern Trust Company, knowing such claims to be false, fictitious, or fraudulent; knowingly 
and willfully falsified, concealed or covered up material facts regarding the Southern Trust 
Company; made false or fraudulent statements or representations about the purpose, activities, 
income, and employment of Southern Trust Company; and made and submitted false affidavits 
knowing the same to contain any fraudulent or fictitious statement or entry. 
404. 
These false statements and documents included affidavits, testimony, an 
application, and other documents that misrepresented that Southern Trust Company was 
engaged in, and failed to disclose it did not and could not carry out, in its stated purpose of 
providing consulting services in financial and biomedical informatics. 
405. 
Defendants knowingly benefited financially and/or obtained other non-financial 
value from participation in the Epstein Enterprise, which has engaged in human trafficking, 
EFTA00161939

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 71 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 70 of 76 
forced labor, sexual servitude, and commercial sexual activity of underage girls and young 
women in knowing and reckless disregard of the laws of the Virgin Islands. 
406. 
At all times material herein, each Defendant conspired with Epstein and other 
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, 
forced labor, and sexual servitude. 14 V.I.C. §604(j). 
407. 
At all times material herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of 
CICO. 14 V.I.C. §600 et seq. 
COUNT TWENTY-FIVE 
Fraudulent Claims Upon the Government—Cypress, Inc.; Maple, Inc.; Laurel, Inc. 
Violation of the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. §.§. 600 et seq. and 14 V.I.C. § 843 
408. 
The Government restates and realleges paragraphs 1 to 407 of this Complaint as if 
fully set forth herein. 
409. 
At all times relevant and material herein, each Defendant directly and indirectly 
participated in or associated with the Epstein Enterprise, an illicit enterprise. 
410. 
Each Defendant engaged in two or more occasions of conduct that constitute 
criminal predicate acts as defined by CICO, including but not limited to making fraudulent 
claims upon the Government. 
411. 
Defendants Cypress, Maple, and Laurel misrepresented the values of their assets 
held and expenses incurred in their annual reporting to the Government of the United States 
Virgin Islands for each of the tax years from 2011 to 2018. 
412. 
Defendant Cypress misrepresented the value of its assets held during each of these 
years by omitting the value of the 49 Zorro Ranch Road, Stanley, New Mexico property that it 
EFTA00161940

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 72 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 71 of 76 
acquired in or about December 2011, and misrepresented the value of its expenses incurred 
during each of these years by omitting the annual amounts of property taxes it paid for the New 
Mexico property. 
413. 
Defendant Maple misrepresented the value of its assets held during each of these 
years by omitting the value of the 9 East 71st Street, New York, New York property that it 
acquired in or about December 2011, and misrepresented the value of its expenses incurred 
during each of these years by omitting the annual amounts of property taxes it paid for the New 
York property. 
414. 
Defendant Laurel misrepresented the value of its assets held during each of these 
years by omitting the value of the 358 Brillo Way, Palm Beach, Florida property that it acquired 
in or about December 2011, and misrepresented the value of its expenses incurred during each of 
these years by omitting the annual amounts of property taxes it paid for the Palm Beach property. 
415. 
Epstein and DefendanUCo-Executor Kahn signed each of Cypress, Maple, and 
Laurel's annual reports for these years in which they represented that "ALL STATEMENTS 
CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE 
TRUE AND CORRECT . ..." 
416. 
Epstein appears to have maintained divided ownership of these properties, 
transferred ownership of them to the Virgin Islands, and then concealed this fact even from 
Virgin Islands authorities in an attempt to shield the properties from any judgment in the states 
where they are located. 
417. 
Defendants' knowingly and willfully made false representations to the 
Government regarding the assets and expenses of Cypress, Maple, and Laurel, and their conduct 
EFTA00161941

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 73 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 72 of 76 
in failing to inform the Government of each company's true assets and expenses, constitute fraud 
upon the Government. 14 V.I.C. § 843. 
418. 
Defendants, through a pattern of criminal activity, acquired and maintained, 
directly or indirectly, an interest in or control of the Epstein Enterprise or of real property. 
419. 
Defendants benefitted directly and indirectly from the pattern of criminal activity 
conducted by the Epstein Enterprise. Defendants knowingly benefitted financially and/or 
obtained non-financial value from participation in the Epstein Enterprise, which has engaged in 
human trafficking, forced sexual servitude, and commercial sexual activity of underage girls and 
young women, in knowing and reckless disregard of the laws of the Virgin Islands. 
420. 
At all material times herein, Defendants engaged in a pattern of criminal activity 
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO, 
14 V.I.C. §§ 600 et seq. 
COUNT TWENTY-SIX 
Fraud Went Claims Upon the Government—Cypress, Inc.; Maple, Inc.; Laurel, Inc. 
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 
14 V.I.C. §§ 600 et seq. and 14 V.I.C. § 843 
421. 
The Government restates and realleges paragraphs 1 to 420 of this Complaint as if 
fully set forth herein. 
422. 
At all material times herein, each Defendant engaged in a conspiracy to commit 
fraudulent conveyances. 
423. 
Each Defendant engaged in acts that revealed its intent to join and participate in 
the criminal conspiracy, including, but not limited to, transferring assets to and between various 
entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder, or delay claims 
against them. 
EFTA00161942

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 74 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 73 of 76 
424. 
These false statements and documents included annual financial statements for the 
years 2011 to 2018 submitted by each Cypress, Maple, and Laurel to the Office of Lieutenant 
Governor of the Virgin Islands that misrepresented the value of the assets held and the amount of 
the expenses incurred by each company during each of these years. 
425. 
Epstein appears to have maintained divided ownership of these properties, 
transferred ownership of them to the Virgin Islands, and then concealed this fact even from 
Virgin Islands authorities in an attempt to shield the properties from any judgment in the states 
where they are located. 
426. 
Defendants knowingly benefitted financially and/or obtained other non-financial 
value from their participation in the Epstein Enterprise, which has engaged in human trafficking, 
forced labor, sexual servitude, and commercial sexual activity of underage girls and young 
women, in knowing and reckless disregard of the laws of the Virgin Islands. 
Notice of Allegation of 
PUNITIVE DAMAGES 
427. 
The purpose of punitive damages in the common law is to punish the defendant 
for outrageous conduct that is reckless or intentional and to deter others from engaging in such 
conduct in the future. 
428. 
This Complaint describes intentional conduct so egregious, persistent, and 
injurious that it shocks the conscience and offends a civilized society. 
429. 
Punitive damages are especially important in the case of persons or companies 
that have so money, assets, and power that mere fines, penalties, and economic damages are 
simply not sufficient. 
EFTA00161943

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 75 of 77 
GVI v. Estate of Jeffrey Epstein 
GVI's Second Amended Complaint 
Page 74 of 76 
430. 
At all times material herein, Epstein and the Epstein Enterprise engaged 
repeatedly in wrongful acts which were intentional and outrageous. The Government gives 
notice that it intends to pursue the possibility of punitive damages in any jury verdict. 
PRAYER FOR RELIEF 
WHEREFORE, the Government respectfully requests that the Court: 
A. 
Enter a judgment in favor of the Government and against Defendants on all 
counts; 
B. 
Declare that Defendants, through the Epstein Enterprise, have engaged in a 
pattern of criminal activity in the Virgin Islands including but not limited to human trafficking, 
forced labor and sexual servitude of female children and young women, unlawful sexual contact, 
child sexual abuse, child abuse and neglect, rape, prostitution civil conspiracy and other offenses 
related offenses, and civil conspiracy; 
C. 
Pursuant to 14 V.I.C. § 610, enforce and maintain the criminal activity liens the 
Government is filing contemporaneously with this lawsuit, or shall file in connection with this 
action; 
D. 
Pursuant to 14 V.I.C. § 607(a)(1) and 14 V.I.C. § 141, issue an order forfeiting 
and divesting in favor of the Government of the Virgin Islands all of Defendants' interests in any 
real and personal property used to facilitate the criminal enterprise carried out by the Epstein 
Enterprise, including but not limited to Little St. James Island and Greater St. James Island; 
E. 
Issue an order forfeiting to the Government of the Virgin Islands any proceeds or 
funds obtained by Defendants, whether directly or indirectly, during the course of the criminal 
activity of the Epstein Enterprise; 
EFTA00161944

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 76 of 77 
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 
EFTA00161945

Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 77 of 77 
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 
EFTA00161946

Casee112226WIDMI4JISR LEXcrateatitLES2
ISM/1MM RazigeLbtfl l 
GOVERNMENT OF THE UNITED 
STATES VIRGIN ISLANDS 
PLAINTIFF, 
V. 
JP MORGAN CHASE BANK, N.A. 
DEFENDANT. 
UNITED STATES DISTRICT COURT FOR THE 
SOUTHERN DISTRICT OF NEW YORK 
Case Number: Oa 
C v
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" (i.e., 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 
EFTA00161947

Glasee1222m(109921433NR CCOcicurnemtlE52 FITI Sal/1MM PRojge22abfiiil 
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 
EFTA00161948

Glasee1J2226WID9944J3I6R C&ccureaa0.E52 RileaDalInZint3 FRoige33:6>flill
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 
EFTA00161949

Casee112226WID9944JISR LEXcattinemtLES2 
 
 Flame41othall 
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 
EFTA00161950

Casee1.1222etAID9921431SR Daccratritemtlf52 Rilttecall.Ing2a3 Ragge55ootal 
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 
EFTA00161951

Casee1.1222m(099214JSIR adecareamtLE52 FlileedDallnant3 Razige6EothtUll 
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 
EFTA00161952

Glasee1J222eiNID99214JORR MecurnemtlI52 RileckiX111ffint3 PRojige77obtal 
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. 
7 
EFTA00161953

Caseel.1222evADMOQISR aktoweemtiES2 
 
 riaggeEft)1111 
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 
EFTA00161954

Casee11222euVIIX1O214)S3R aaeatmeatitlE52 RilttalDallnant3 PRoa€99othtill 
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 
EFTA00161955