Case 1:22-cv-10904-JSR Document 34 Filed 01/26/23 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 09044 SR PLAINTIFF, V. JPMORGAN CHASE BANK, N.A. DEFENDANT. MOTION FOR ISSUANCE OF LETTER OF REQUEST FOR DOCUMENT PRODUCTION 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 Barclays Bank PLC, located at I Churchill Place, London El4 5HP, United Kingdom, to produce discovery documents requested by Plaintiff, which are set forth in the Letter of Request for Document Production and Schedule A attached hereto, in digital and/or hard copy form. As grounds for this Motion, the Plaintiff states the following: The above captioned case is currently pending in the United States District Court for the Southern District of New York. The Government of the United States Virgin Islands ("Government") brought this civil action against JPMorgan Chase Bank, N.A. ("JPMorgan") as part of its ongoing effort to protect public safety and to hold accountable those who facilitated or participated in, directly or indirectly, the trafficking enterprise Jeffrey Epstein ("Epstein") helmet The Government's investigation revealed that JPMorgan knowingly, negligently, and unlawfully provided and pulled the levers through which recruiters and victims were paid and was EFTA02805942