Case 1:22-cv-10904-JSR Document 100 Filed 03/27/23 Page 1 of 5 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/Third-Party Plaintiff. JPMORGAN CHASE BANK, N.A. Third-Party Plaintiff, V. JAMES EDWARD STALEY Third-Party Defendant. ) ) ) ) ) ) ) ) ) ) Case Number l :22-cv-10904-JSR ) ) ) ) ) ) ) ) ) ) STIPULATED MOTION FOR APPROVAL OF PROTOCOL FOR REVIEW OF VIDEOMATERIALS AND PHOTOGRAPHS FOR THE PRESENCE OF POTENTIAL CHILD SEX ABUSE MATERIALS AND FOR DISCLOSURE OF THOSE MATERIALS Plaintiffs Jane Doe 1 and the Government of the United States Virgin Islands ("Government"), by their respective counsel, move pursuant to Federal Rules of Civil Procedure 26(c), and the authority of the Court to administer proceedings before it, for approval of an agreedupon protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videorecorded materials and photographs in the possession, custody, or control of the Epstein Estate (the "Epstein Media") in response to subpoenas previously issued by Jane Doe I and, to the extent responsive to those subpoenas, disclose relevant portions of the Epstein Media EFTA02806784