Case Document Filed Page of Case Document Filed Page of revealed that JPMorgan financially profited from the deposits made by Epstein and Epstein controlled entities located in the Virgin Islands and from the business opportunities referred to JPMorgan by Epstein and his co-conspirators in exchange for its known facilitation of and implicit participation in Epsteins sex trafficking venture Upon information and belief Larry Page-the co-founder and co-owner of Alphabet Inc Google LLCs parent company is a high-net-worth individual who Epstein may have referred or attempted to refer to JPMorgan Mr Page announced in that he was stepping down as CEO of Google LLC and Alphabet but would remain actively involved as a Board Member Shareholder and Co-Founder See Alphabet Inc Alphabet management change Dec attached as Exhibit The Government issued a subpoena for documents to Mr Page on April attached as Exhibit The Government made good-faith attempts to obtain an address for Larry Page including hiring an investigative firm to search public records databases for possible addresses Declaration of Mimi Liu Liu Deel attached as Exhibit Our process server attempted service at the addresses identified by our investigative firm but discovered the addresses were not valid for Mr Page Liu Deel Due Diligence Affidavits of Andrey Alekseev and Douglas Henry collectively attached as Exhibit This Court long has recognized that Rule of the Federal Rules of Civil Procedure permits alternative service of a subpoena by certified mail where a party is unable to provide personal service in accordance with the interpretive principle that the rules be construed and administered to secure the just speedy and inexpensive determination of every action Cordius Trust Kummeifeld Fed Serv 3d WL at S.D.N.Y Jan quoting Fed Civ The Court has permitted alternative service where a partys repeated Case Document Filed Page of Case Document Filed Page of attempts at personal service have failed see SEC David No WL at S.D.N.Y Feb Rakoff or where there is an approaching close of discovery In re Petrobras Securities Litig No WL at S.D.N.Y March Rakoff authorizing alternative service by email and overnight mail days before April discovery end date Both circumstances are present here The Government has made good-faith efforts to obtain an address for Mr Page and to serve a subpoena upon him personally Moreover the fact discovery end date is at the end of this month In these circumstances the Court should in the interest of securing just and expeditious resolution authorize the Government to provide alternative service by serving Mr Page by service upon Alphabet Inc.s registered agent Dated May ARIEL SMITH ESQ ATTORNEY GENERAL NOMINEE By counsel ls/Mimi Liu Mimi Liu pro hac vice Linda Singer pro hac vice David I Ackerman Paige Boggs pro hac vice MOTLEY RICE LLC 9th Street NW Suite Washington DC Tel Fax lsinger motleyrice.com mliu motleyrice.com dackerman motleyrice.com pboggs motleyrice.com
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