Case 1 22-cv-10904-JSR Document 282 Filed 08/14/23 Page 1 of 18 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. Defendantahird-Party Plaintiff. JPMORGAN CHASE BANK, N.A. Third-Party Plaintiff, V. JAMES EDWARD STALEY ) ) ) ) ) ) ) ) Case Number: I :22-ev- I 0904-J SR ) ) ) ) ) ) ) ) Third-Party Defendant. GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' RESPONSE TO DEFENDANT'S LOCAL CIVIL RULE 56.1(B) COUNTERSTATEMENT OF ADDITIONAL MATERIAL FACTS Pursuant to the Court's leave granted during the August 11, 2023 teleconference, Plaintiff Government of the United States Virgin Islands ("the Government") respectfully submits these summary responses to the paragraphs of Defendant JPMorgan Chase Bank, N.A.'s ("JPMorgan") Counterstatement of Additional Material Facts (Dkt. 255 at 230-302) ("CSMF") that deal exclusively with JPMorgan's Affirmative Defenses. In so doing, the Government does not admit or waive objections to paragraphs of the Counterstatement relating to the Government's affirmative claims. As discussed on the phone call, the Government proceeds in summary fashion so as to present these responses in as concise a manner as possible. EFTA02814983