MT. PLEASANT, SC | PROVIDENCE, RI | HARTFORD, CT | WASHINGTON, DC | NEW YORK, NY  
MORGANTOWN, WV | CHARLESTON, WV | PHILADELPHIA, PA | CHERRY HILL, NJ 
 
  
 
 
 
 
    
 
 
 
 
 
 
 
www.motleyrice.com
“I will stand for my client’s rights. 
I am a trial lawyer.” 
–Ron Motley (1944–2013) 
401 9th St. NW, Suite 630
Washington, DC 20004
o. 202.232.5504    f. 202.232.5513 
David I. Ackerman 
Licensed in DC, NJ, NY 
direct: 202.849.4962 
dackerman@motleyrice.com 
December 22, 2022 
 
Via ECF and Email 
 
Hon. John P. Cronan  
United States District Court 
Southern District of New York  
500 Pearl Street, Room 1320  
New York, NY 10007 
CronanNYSDChambers@nysd.uscourts.gov 
 
Re:  
Government of the United States Virgin Islands v. JP Morgan Chase & Co.  
(1:22-mc-00365-JPC) 
 
Dear Judge Cronan:  
 
 
The Government of the United States Virgin Islands (“Government”) filed a Motion to File 
Civil Case Under Seal (“Motion”) on December 20, 2022 in the above-referenced matter.  After 
the Court entered its Order on December 21, 2022 granting the Motion, the Government met and 
conferred with counsel for JP Morgan Chase & Co. (“JP Morgan”).  JP Morgan’s counsel 
requested, and the Government has agreed, to: (1) provisionally redact Paragraphs 42, 50, 57, and 
62 in addition to the other redactions shown in the Government’s proposed redacted complaint 
attached to the  Motion; and (2) substitute JP Morgan Chase & Co. with JPMorgan Chase Bank, 
N.A.  As such, the parties respectfully request that the Court enter the attached agreed Order, which 
would allow the Plaintiff to slightly modify its redacted and unredacted complaints as described.   
 
 
If Your Honor would like the parties to proceed in a different manner, such as filing a new 
Motion for Leave to File Civil Case Under Seal, the parties are prepared to do so at the direction 
of the Court.   
 
Sincerely,  
 
/s/ David I. Ackerman  
 
David I. Ackerman 
 
cc: 
Carol Thomas-Jacobs, Esq., carol.jacobs@doj.vi.gov (Counsel for the Government) 
 
Linda Singer, Esq., lsinger@motleyrice.com (Counsel for the Government)  
 
Boyd Johnson, Esq., Boyd.Johnson@wilmerhale.com (Counsel for JP Morgan) 
 
Felicia Ellsworth, Felicia.Ellsworth@wilmerhale.com (Counsel for JP Morgan) 
 
Case 1:22-mc-00365-JPC   Document 4   Filed 12/22/22   Page 1 of 1