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.
A Bloomberg article from October 4, 2017, details Greg Fleming's appointment as CEO of the newly formed Rockefeller Capital Management. The firm, created in partnership with the Rockefeller family office, is set to be acquired by Viking Global Investors. The document is stamped with a House Oversight Bates number.
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