Case Document Filed Page of EXHIBIT Case Document Filed Page of DocuSign Envelope ID UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Jane Doe Individually and on behalf of all others similarly situated Plaintiff vs JPMorgan Chase Bank N.A Defendant CASE NO JSR I JPMORGAN CHASE BANK N.A.S SUPPLEMENTAL RESPONSES AND OBJECTIONS TO PLAINTIFFS FIRST Case Document Filed Page of DocuSign Envelope ID responses are given without prejudice to its rights to introduce at trial evidence of any subsequently discovered or unintentionally omitted facts or documents To the extent JPMC responds to a specific interrogatory below JPMC does not admit to Plaintiffs characterization of any documents facts theories or conclusions JPMCs responses to the Interrogatories do not constitute acquiescence or agreement to any definition proposed by Plaintiff JPMCs objections and responses are made without in any way waiving or intending to waive but to the contrary are intended to preserve All questions as to competency relevancy materiality privilege and admissibility as evidence for any purpose of the responses or subject matter thereof in this action or any subsequent proceeding associated with this action or any other matter The right to object on any ground to the use of said responses or the subject matter thereof in any subsequent proceeding associated with this action or any other matter and The right to object at any time to other requests or other discovery procedures involving or relating to the subject matter of these Interrogatories GENERAL OBJECTIONS JPMC incorporates by reference the General Objections asserted in JPMorgan Chase Bank N.A Responses and Objections to Plaintiffs First Set of Intenogatories served on February OBJECTIONS TO DEFINITIONS JPMC incorporates by reference the Objections to definitions asserted in JPMorgan Chase Bank N.A Responses and Objections to Plaintiffs First Set of Intenogatories served on February Case Document Filed Page of DocuSign Envelope ID SPECIFIC RESPONSES INTERROGATORY NO List any high net-worth clients or businesses the introduction or relationship between that person or entity of which was facilitated by Jeffrey Epstein RESPONSE TO INTERROGATORY NO In addition to and specifically incorporating its foregoing General Objections and Objections to Definitions JPMC objects to Interrogatory No because it would be more convenient less burdensome and less expensive to obtain the identity of individuals at JPMC through requests for production under Rule Fed Civ i JPMC also objects to Interrogatory No because the terms high net worth introduction facilitated and relationship are vague and ambiguous Subject to and without waiving its objections and based upon a reasonable and diligent investigation JPMC states that Mr Epstein had some involvement in the establishment of customer relationships between JPMCs private bank and Ghislaine Maxwell and Kathryn Ruemmler If JPMC learns of others it will supplement this answer INTERROGATORY NO Identify all JPMorgan officers and employees with knowledge of information relevant to whether JPMorgan made any changes to policies procedures protocols or practices as a consequence of its relationship with Jeffrey Epstein and/or any Epstein-related individual and entity or any public or negative attention it received due to those relationships RESPONSE TO INTERROGATORY NO In addition to and specifically incorporating its foregoing General Objections and Objections to Definitions JPMC objects to Interrogatory No on the grounds that it is overly broad unduly burdensome and seeks information that is not relevant to any partys claims or defenses Fed Civ JPMC also objects to Interrogatory No because it seeks information that can be obtained from a more convenient less burdensome or less expensive Case Document Filed Page of DocuSign Envelope ID source such as requests for production of documents under Rule or depositions under Rule Fed Civ i JPMC further objects to Inte1rngatoryNo because the phrases information relevant to whether JPMC made changes and as a consequence of its relationship and public or negative attention are vague and ambiguous Subject to and without waiving its objections and based upon a reasonable and diligent investigation JPMC did not make any changes to policies procedures protocols or practices during the period from to as a consequence of its relationship with Jeffrey Epstein and/or any Epstein-related individual or entity or any public or negative attention it received due to those relationships Dated April Respectfully submitted Boyd Johnson I Robert Boone Hillary Chutter-Ames World Trade Center Greenwich Street New ode NY boyd.johnson wilmerhale.com robert.boone wilmerhale.com hillary.chutter-ames wilmerhale.com Felicia Ellsworth John Butts State Street Boston MA felicia ellsworth wilmerhale.com john butts wilmerhale.com Case Document Filed Page of DocuSign Envelope ID Attorneys for Defendant JP Morgan Chase Bank N.A Case Document Filed Page of DocuSign Envelope ID VERIFICATION OF INTERROGATORY ANSWERS I Francis Peam state that based on reasonable inquiry including a review of documents and information provided by other employees of JPMorgan Chase Bank N.A and counsel the foregoing answers are true and correct to the best of my knowledge information and belief I verify under penalty of perjury that the foregoing is hue and correct DATED April NewYork,NY Francis Pearn By Francis Peam Case Document Filed Page of DocuSign Envelope ID CERTIFICATE OF SERVICE I hereby certify that on April the foregoing document titled JPMorgan Chase Bank N.A.s Supplemental Responses and Objections to Plaintiffs First Set of Interrogatories was served in accordance with the Federal Rules of Civil Procedure and the Local Rules of the United States District Court for the Southern District of New York upon the attorneys for the plaintiff in the above-entitled action by electronic mail DATED April New York NY Jb6 By John Butts
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