MARILYN EZZES, Individually and on Behalf of All Others Similarly Situated, Case No. 2:22-cv-01915-GMN-DJA Plaintiff,

WHEREAS, on May 1, 2023, Lead Plaintiffs Marilyn Ezzes and Jeffrey A. Davies filed the Consolidated Amended Class Action Complaint (ECF No. 36); WHEREAS, on June 30, 2023, Defendants filed a Motion to Dismiss the Consolidated Amended Class Action Complaint (ECF No. 39); WHEREAS, on August 14, 2023 Lead Plaintiffs filed a Response to the Motion to Dismiss (ECF 43) to which Defendants filed a Reply on September 25, 2023 (ECF No. 44); WHEREAS, on March 1, 2024, the Court entered an Order granting the Motion to Dismiss with leave to file a further amended complaint within 21 days of the date of the Order, which falls on March 22, 2024 (ECF No. 45); WHEREAS, counsel for Lead Plaintiffs represents that they already had numerous deadlines in other cases already in place within this 21 days; WHEREAS, counsel for Lead Plaintiffs represents they have been diligently working on a Second Consolidated Amended Complaint; WHEREAS, counsel for Lead Plaintiffs represents that as soon as they determined that additional time is required to fully address the issues identified by the Court in the Order, they promptly contacted counsel for Defendants; and WHEREAS, counsel for Lead Plaintiffs have conferred with counsel for Defendants regarding an extension of the deadline to file a further amended complaint and Defendants’ anticipated motion to dismiss; IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel, and subject to Court approval, that:

MARILYN EZZES, Individually and on Behalf of All Others Similarly Situated, Case No. 2:22-cv-01915-GMN-DJA

DEVILLERS, and KRISTINA JOHNSTON, Defendants Having considered the parties’ Joint Stipulation Extending Lead Plaintiff’s Deadline to File a Second Consolidated Amended Complaint and Defendant’s Response Thereto, and good cause appearing therefore,

Lead Plaintiffs shall file a Second Consolidated Amended Complaint on or before April 5, 2024.

Documents Or Other Property To Be Inspected None. 14.

Documents Or Other Property To Be Inspected None. 14.

THIS MATTER having come before the Court on the joint letter motion of Plaintiff Essilor Manufacturing (Thailand) Co., Ltd. (“EMTC”) and Defendant JPMorgan Chase Bank, N.A.

(“JPMC”) to Appoint Commissioner for Depositions in France and for Issuance of Requests for International Judicial Assistance under Article 17 of the Hague Convention (Dkt. ___),

That the Requests for International Judicial Assistance in the Authorization of a Commissioner Pursuant to Chapter II, Article 17 of the Hague Convention on the Taking of

Case 1:22-cv-03361-LJL Document 103-1 Filed 03/11/24 Page 3 of 3Case 1:22-cv-03361-LJL Document 104 Filed 03/12/24 Page 3 of 3 Evidence Abroad in Civil or Commercial Matters in France from Essilor International SAS and JPMorgan Chase Bank, N.A., attached to this Order as Exhibits 1 and 2 (the “Requests”), are hereby issued as the Court’s requests and are incorporated herein;

That counsel for the Parties file, or request the Commissioner to file, this signed Order and the Request, along with French translations of both documents, with the Ministère de la Justice, Direction des Affaires Civiles et du Sceau, Département de l’entraide, du droit international privé et européen (DEDIPE), 13, Place Vendôme, 75042 Paris Cedex 01, within ten (10) business days of the entry of this Order.

Defendants.

──────────────────────────────────── JOHN G. KOELTL, District Judge: The defendants are directed to provide the Court with paper courtesy copies of all papers filed in connection with the fully briefed motion to dismiss.

ECF Nos. 49 and 53.

John G. Koeltl United States District Judge

In fact, none of the allegations link FE 1 to a single named Defendant.

Nonetheless, FE 1’s hearsay statement by an anonymous colleague stating, “Kathy’s numbers are screwed up,” is not sufficiently reliable.

Even if non- defendant managers or executives found the calculations to be incorrect, none of FE 1’s statements indicate that these complaints were relayed to CFO DeVillers.

Case 22-1879, Document 127, 12/12/2023, 3597464, Page1 of 1 United States Court of Appeals

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 12th day of December, two thousand twenty-three.

Present: Guido Calabresi, José A. Cabranes, Joseph F. Bianco, Circuit Judges.

The parties are hereby advised that consideration of this appeal will be held in abeyance pending this Court’s issuance of its decision in Commerzbank AG v. U.S. Bank, N.A.

It is ORDERED that, no later than fourteen days after issuance of that decision, each party shall submit to this Court a letter brief, not to exceed fifteen pages double-spaced, addressing the effect, if any, that the Commerzbank AG v. U.S. Bank, N.A.

None of this would be privileged because the document is being used for the business purpose of approving a set of non-standard terms.

... Prasad, Pranav <pranav. prasad@jpmorgan.com> CDMC Essilor & - 11/22/2016 2:25:00 AM 11/22/2016 2:55:00 AM Free Recurrence: Required Attendees: Attachments: (none) Hongrattanakulchai, Phiroon: Pon, Patrique BC ...

), 2008 WL 4962985, at *1 (S.D.N.Y. Nov. 20, 2008) (“Reconsideration is appropriate only where there is an intervening change of controlling law, newly available evidence, or the need to correct a clear error or prevent manifest injustice.” (internal quotes omitted)).

However, based solely upon BSA/AML/ KYC-based objections, JPMC refused to produce all but one type of document (showing “the final results of any formal reviews concerning the Fraudulent Transfers”).

So contrary to your characterizations, the urgency of ascertaining JPMC’s position is not “moot.” Please promptly tell us what JPMC will and will not produce in response to RFPs 9, 52-57, 59 and 93 (other than the “final results of any formal reviews” of the Fraudulent Transfers – “if any exist”5), from what custodians and for what time periods.

In addition to withholding training materials on other relevant subjects (e.g., marketing JPMC’s commercial banking services, operating JPMC’s monitoring system, and the disputed AML and KYC procedures), JPMC’s failure to make a custodial production in 5 See, e.g., JPMC R&Os to RFPs 9 and 57.

response to these RFPs withholds discovery of precisely what, if any, training communications and materials the percipient JPMC witnesses actually received (e.g., in the wire rooms).

: ESSILOR INTERNATIONAL SAS and :

LEWIS J. LIMAN, United States District Judge: Plaintiffs, Defendant.

The motion for reconsideration is granted in part and denied in part.

The Court has reviewed in camera the document at Dkt. No. 70-2.

The remainder of the redactions pertain to privileged information and are appropriate.

LEWIS J. LIMAN, United States District Judge: Plaintiff Essilor Manufacturing (Thailand) Co., Ltd. (“EMTC”) moves, pursuant to Federal Rule of Civil Procedure 37(a)(3)(A), for an order compelling Defendant J.P. Morgan Chase Bank, N.A.

(“JPMC”), to produce three previously redacted emails and attachments, allegedly protected by attorney-client privilege, in unredacted form, and to perform supplemental searches for related documents.

The remaining two documents of which EMTC seeks unredacted versions of are forms submitted to JPMC’s Client Deal Management Committee (“CDMC”) for approval of non- standard account terms.

The CDMC is comprised of senior representatives across several JPMC functions, including the Legal Department.

Absent a motion for reconsideration, the letters at Dkt. Nos. 70 and 73 shall be filed on the public docket in unredacted form no later than November 28, 2023.

: ESSILOR INTERNATIONAL SAS and :

Plaintiffs, Defendant.

LEWIS J. LIMAN, United States District Judge: The defendant shall produce 70-2, 70-6 and 70-8 with attachments to the court for in camera review.

The documents shall be filed under seal with access limited to the court and to the defendant.