This document is a Memorandum of Law in Support of Defendants' Motion to Dismiss, filed in the United States District Court for the Southern District of New York in the derivative litigation against JP Morgan Chase & Co. It outlines arguments regarding pleading standards, demand futility, and failure to state claims against the defendants, including specific points related to JPMorgan's termination of Epstein as a client and the oversight of internal controls by the board of directors. The document includes a table of authorities citing numerous legal cases.
This document is a page from a Bank of America Merrill Lynch equity strategy report dated January 29, 2017. It contains two tables analyzing S&P 500 companies: one listing companies with high effective tax rates and low foreign sales, and another listing companies likely to benefit from repatriation due to high overseas cash reserves (e.g., Apple, Microsoft, Cisco). The document bears a 'HOUSE_OVERSIGHT_023088' stamp, indicating it was produced as evidence for the House Oversight Committee, though the text itself contains no direct references to Jeffrey Epstein or his associates.
The document is a conspiratorial narrative linking the suspicious death of Justice Scalia to broader 'murder ops' and corporate corruption involving SAIC, Tetra Tech, and government contracts. It details the career movements of Bud and Sue Horton between IBM, Accenture, and Tetra Tech, alleging their involvement in securing billion-dollar contracts with the State Department and DoD that purportedly facilitated the Afghan heroin trade. The text also references the 'Franklin Scandal' and criticizes the lack of autopsy for Justice Scalia.
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