Case 1:22-cv-10904-JSR Document 65 Filed 03/03/23 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, Plaintiff, v. JPMORGAN CHASE BANK, N.A., Defendant. ) ) ) ) ) ) ) ) ) Case No. 1:22-cv-10904-JSR ) ) ) GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' MOTION FOR ORDER AUTHORIZING ALTERNATIVE SERVICE OF SUBPOENA BY CERTIFIED MAIL AND EMAIL UPON a/k/a NOW COMES the Government of the United States Virgin Islands, the Plaintiff in the above-captioned action, and moves pursuant to Fed. R. Civ. P. 45 for an Order authorizing the Government to provide alternative service by certified mail and email of a Subpoena to Produce Documents upon non-party a/k/a . As grounds for this Motion, the Government states the following: The Government brought this civil action against Defendant 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 of Jeffrey Epstein ("Epstein"). The Government's investigation has revealed that JPMorgan knowingly, recklessly, and unlawfully provided and pulled the levers through which Epstein's recruiters and victims were paid and was indispensable to the operation and concealment of the Epstein trafficking enterprise. Financial institutions can connect—or choke—human trafficking networks, and enforcement 1 EFTA02806354