Epstein Secrets

Don LLP 60 State Street Boston, Massachusetts 02109 Tel: (617) 526-6000 [email protected] [email protected] Counsel for ,IPMorgan Chase Bank, N.A. 37 EFTA01652928 Case 1:22-cv-10019-JSR Document 181-2 Filed 06/22/23 Page 1 of 13 EXHIBIT A-1 EFTA01652929 Case 1:22-cv-10019-JSR Docum

igible Class Members: Defendant; members of the Immediate Family of any Defendant who is an individual; current and former directors and officers of JPMorgan Chase Bank N.A.; Defendant's current and former legal representatives, heirs, successors, or assigns, and any entity in which Defendant has or had a controlling int

n, and (ii) requests such a meeting. f. Trtitgi : The Claims Administrator shall provide in writing to Claimants' Counsel and counsel for JPMorgan Chase Bank, N.A., simultaneously and in a manner that ensures confidentiality, the Allocated Amounts for all Participating Claimants on the same date within a

ending final approval of this Settlement no later than two business days after filing the petition. JPMC shall withdraw any pending petition before the Second Circuit within two business days of the Effective Date. 1.5 "Class Member" or "Member of the Class" means a Person who falls within the definition of the

From: "Miller, Michael" < To: ' Cc: Reid" "Weingarten, "Lucas, Morgan" Subject: United States of America v. Epstein U.S. - 2nd Circuit Docket No. 19-2221 Date: Tue, 20 Aug 2019 14:56:58 +0000 Attachments: Draft_Stipul

From: "Miller, Michael" < To: ' Cc: Reid" "Weingarten, "Lucas, Morgan" Subject: United States of America v. Epstein U.S. - 2nd Circuit Docket No. 19-2221 Date: Tue, 20 Aug 2019 14:56:58 +0000 Attachments: Draft_Stipulation_to_Withdraw_Appeal-c2.DOC 0 - If you can sign and return t

to fill out financial disclosure forms. He has an account at Chase Manhattan. If they want to see that, fine. This is not as if he's stealing from Chase Manhattan, but it involves all the efforts that he is attempting to undertake with regard to obtaining restitution. That does strike us as not assisting him

ying to collect this money is a bit of, as I said, a scarlet letter and the court cases, as you know, talk about this a great deal, particularly in the Second Circuit. The financial disclosure forms, again, strikes me that that is a little uncertain. He's certainly willing to fill out financial disclosure forms.

ut 7 financial disclosure forms. He has an account at Chase 8 Manhattan. If they want to see that, fine. This is not as if 9 he's stealing from Chase Manhattan, but it involves all the 10 efforts that he is attempting to undertake with regard to 11 obtaining restitution. That does strike us as not assist

o collect this money is a bit of, as I said, a scarlet 3 letter and the court cases, as you know, talk about this a 4 great deal, particularly in the Second Circuit. 5 The financial disclosure forms, again, strikes me that 6 that is a little uncertain. He's certainly willing to fill out 7 financial disclosu

ent along with a copy of the Court's order directing the witness to comply with the subpoena or face sanctions. Id. at *3. Similarly, in ../PMorgan Chase Bank, N.A. v. IDW Grp., LLC, No. 08 CIV. 9116(PGG), 2009 WL 1313259, at *3 (S.D.N.Y. May 11, 2009), this Court allowed service of a deposition subpoena

a subpoena to the door, and mailing another copy to counsel of record was sufficient). Cases not only from this Court, but also from others in the Second Circuit, have interpreted that rule "liberally" to allow service so long as the "the type of 7 EFTA00617957 Case 1:15-cv-07433-RWS Document 160 Filed 05/

uit's acknowledgment that the retroactivity of the 2003 Amendment must be analyzed under Landgraf. Weingarten v. United States, 865 F.3d 48, 54-58 (2d Cir. 2017). 3 No Landgraf analysis was performed, nor was Congress' rejection of the retroactivity provision discussed, in United States v. Brown, 800 F

x, 527 U.S. 343, 355-57 (1999) (examining "structure and legislative history" as part of first Landgraf step). And as the government acknowledges, "the Second Circuit has considered both the text of the statute and the legislative history" at the first Landgraf step. Opp. 28 (citing In re Enterprise Mortgage Acce

e, which has nothing to do with sentencing, immigration, or prior convictions, to refer to the elements of the offense. See, e.g., United States v. Morgan, 393 F.3d 192, 198 (D.C. Cir. 2004) ("The most natural reading of § 3237(a) ¶ 2 is to construe `any offense involving' by reference to the elements

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