General Objections and these objections, Highbridge will undertake a reasonable search
for and produce responsive documents.
Request No. 7: All documents concerning Jeffrey Epstein's involvement in J.P.
Morgan's investment in Highbridge Capital Management, including but not limited to the
introduction of Glenn Dubin to Jes Staley.
Response to Request No. 7:
Highbridge objects to this Request on the grounds that it is overly broad, unduly
burdensome, and seeks information that is irrelevant and not calculated to lead to the
discovery of admissible evidence.
Request No. 8: All documents concerning this arbitration.
Response to Request No. 8:
Highbridge objects to this Request on the grounds that it is vague, overly broad,
unduly burdensome, and seeks information that is irrelevant and not calculated to lead to
the discovery of admissible evidence. Highbridge further objects to this request because
it seeks information more easily available from a party. Subject to and without waiving
its General Objections and these objections, Highbridge will undertake a reasonable
search for and produce documents relating to the arbitration and the Third-Party
Claimants' investments in the Fund.
Request No. 9: All documents concerning the Settlement Agreement and
Release.
Response to Request No. 9:
Highbridge objects to this Request on the grounds that it is overly broad, unduly
burdensome, and seeks information that is irrelevant and not calculated to lead to the
discovery of admissible evidence. Subject to and without waiving its General Objections
9
Confidential Treatment Requested by JPMorgan Chase JPM-SDNY-00061127
EFTA01581722