Case 1:22-cv-10904-JSR Document 27 Filed 01/20/23 Page 1 of 3 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS Case Number: I :22-cv-I 0904-JSR PLAINTIFF, V. JPMORGAN CHASE BANK, N.A. DEFENDANT. MOTION FOR ISSUANCE OF LETTER OF REQUEST (LETTER ROGATORY) NOW COMES, the Plaintiff, in the above referenced action, and moves for the Issuance of a Letter of Request (Letter Rogatory) pursuant to F.R.C.P. 28 requesting an order requiring Cathy Alexander, located at 7 Harmonie Crescent, Paradise Beach, Jeffreys Bay 6330, South Africa, to do the following: (a) Appear to have her remote deposition taken on a date to be agreed within 30 days of service of the subpoena at a mutually convenient location in or near Jeffreys Bay; and (b) Produce all Documents, Communications, and agreements related to her employment by Jeffrey Epstein, including: I. Employment and agreements, 2. Non-disclosure agreements, 3. All payments, in any form, received from or on behalf of Jeffrey Epstein, and 4. All Communications with Jeffrey Epstein, Ghislaine Maxwell, Bella Klein, Daphne Wallace. Harry Beller, Lesley Groff, aAc/a Erika Kellerhals, Richard D. Kahn, and/or Darren K. Indyke. EFTA02805800