HomeMy WebLinkAboutResolution - 2012-R0308 - Authorize Settlement - JP Morgan & Chase & Co. - 08/09/2012Resolution No. 2012—RO308
August 9, 2012
Item No. 5.4
RESOLUTION
E IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF LUBBOCK:
THAT the Mayor of the City of Lubbock is hereby authorized and directed to
cecute for and on behalf of the City of Lubbock settlement documents in connection
ith an out-of-court settlement reached between Various State Attorneys General and J.
Morgan & Chase & Co. ("JPMC") concerning alleged violations of state and federal
ititrust and other laws by JPMC and other providers, brokers and advisors involving the
marketing, sale, and placement of Municipal Bond Derivaties. Said settlement documents
are attached hereto and incorporated in this Resolution as if fully set forth herein and shall
be included in the minutes of the Council.
Passed by the City Council this
ATTEST:
August 9 2012.
ID '-�v -
Rebecca Garza, City Secretary
APPROVED AS TO CONTENT:
Lee Ann Dumbauld, City Manager
APPROVED AS TO FO
Attorney
Res/JP Morgan Chase & Co 7.27.12
RESOLUTION
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THAT the Mayor of the City of Lubbock is hereby authorized an /directed to
execute for and on behalf of the City of Lubbock settlement document in connection
with an out-of-court settlement reached between Various State Attorne s General and J.
P. Morgan &Chase & Co. (`UPMC") concerning alleged violations f state and federal
antitrust and other laws by JPMC and other providers, brokers and dvisors involving the
marketing, sale, and placement of Municipal Bond Deriv ves. Said settlement
documents are attached hereto and incorporated in this Res�iution as if fully set forth
herein and shall be included in the minutes of the Council. /
Passed by the City Council this
fir --1I
Rebecca Garza, City Secretary
(APPROVED AS TO
Dumbapfd, City Manager
APPROVED AS TO
ite;
P Morgan Chase & Co 7.27. 12
2012.
GLEN C. ROBERTSON, MAYOR
JPMC Muni Bond Derivative Settlement
Go GCG
Claims Administrator
P.O. Box 9864
Dublin, OH 43017-5764
(877) 311-1632
CMB0200045623
CITY OF LUBBOCK
TOM MARTIN, MAYOR
1625 13TH ST
LUBBOCK, TX 79401
July 9, 2012
NOTICE LETTER
CMB
Claim No: CMB01000457
YI�NIIAI6NIII�1
RECEIVED
.12 2012
Re: A $65.5 Million Fund Created as the Result of an Out -of -Court Settlement Between Various State Attorneys
General and JP Morgan Chase & Co.
Dear Eligible Counterparty:
This letter and the accompanying forms contain important information about your eligibility to share in a
$65.5 million settlement fund (the "Fund") established pursuant to an out -of -court settlement between JP Morgan
Chase & Co. ("JPMC") and 25 States Attorneys General to resolve matters more specifically explained in "An
Agreement Among the Attorneys General of the States and Commonwealths of Alabama, California, Colorado,
Connecticut, District of Columbia, Florida, Idaho, Illinois, Kansas, Maryland, Massachusetts, Michigan, Missouri,
Montana, Nevada, New Jersey, New York, North Carolina, Ohio, Oregon, Pennsylvania, South Carolina, Texas,
Tennessee and Wisconsin and JP Morgan Chase & Co." dated July 7, 2011 (referred to herein as either the
" u
Settlement Agreement" or the Settlement"). A full copy of the Settlement Agreement can be obtained by visiting
www.stateAGmunisettlement.com. Capitalized terms used herein and the accompanying forms shall have the same
meanings as specified in the Settlement Agreement, unless otherwise noted.
What this Packet Includes: This packet includes: (1) This Notice Letter; (2) an Election to Participate;
(3) a Release Form ("Release"); and (4) a Question and Answer Pamphlet.
Your Eligibility You have been identified as an Eligible Counterparty because you (1) entered into one
or more Municipal Bond Derivative transactions between (i) January 1, 2001 and December 31, 2004,
inclusive, for Municipal Bond Derivatives awarded through a competitive bidding process; or (ii)
January 1, 2001 and December 31, 2005, inclusive, for Municipal Bond Derivatives awarded through
other than a competitive bidding process; (2) where the provider of the Municipal Bond Derivative who
won the bid was JPMC; and (3) the Municipal Bond Derivative has been alleged by the Attorneys
General to have been impacted by the Relevant Conduct described in the Settlement Agreement.
Requirements: In order to receive a share of the $65.5 million Fund, you must complete and submit to
the Claims Administrator both the (1) Election to Participate form and (2) the executed Release. Your
submission must be postmarked no later than August 23, 2012.
Your Share: As identified in paragraph 1 of the Release, if you elect to participate in the Settlement you
will receive a payment of $258,671.20.
Release: By signing the Release, you give up your right to sue JPMC for certain claims, which include
claims being brought against JPMC in civil class actions consolidated in the case of In re Municipal
Derivatives Antitrust Litigation, described further below.
You also give up your right to participate in JPMC's settlement of In re Municipal Derivatives Antitrust
Litigation, described further below. Your recovery, if any, against JPMC in a lawsuit could be greater
or less than your share under the Settlement Agreement.
As noted above, you may review the Settlement Agreement in its entirety at www.stateAGmunisettlement.com. What
follows is (1) a brief summary of the Settlement Agreement; (2) a brief description of the In re Municipal Derivatives
Antitrust Litigation; and (3) instructions on how to receive payment under the Settlement Agreement and other
information. You may also refer to the enclosed Question and Answer Pamphlet for more information.
General Description and Summary of the Settlement Agreement
The Settlement Agreement describes the details of an investigation conducted by certain Attorneys General
that began in the Spring 2008. The investigation concerns alleged violations of state and federal antitrust and other
laws by JPMC and other providers, brokers and advisors, involving the marketing, sale and placement of Municipal
Bond Derivatives. The State Attorneys General have alleged in the Settlement Agreement that: (i) certain JPMC
employees participated in an illegal scheme with brokers and other providers with whom they had relationships to put
their mutual pecuniary interest ahead of those of the Municipal Bond Derivative clients they represented; (ii) JPMC and
other providers and brokers were principal players in the conduct and obtained unjust profits as a result; and (iii) the
wrongful conduct caused certain Issuers throughout the United States to be paid artificially suppressed rates or yields
on Municipal Bond Derivative transactions that were the subject to the conduct. JPMC has cooperated in the
investigation by voluntarily disclosing evidence related to its role in the Relevant Conduct and by agreeing to pay
restitution to parties injured by the Relevant Conduct.
Following an investigation by the Attorneys General in which they determined that not all municipal bond
derivative transactions entered into by JPMC were affected, JPMC and the Attorneys General entered into the
Settlement Agreement whereby, among other things, JPMC agreed to pay restitution to Eligible Counterparties in
return for a Release of claims against JPMC (as defined in the Release). By claiming from the Fund, you will not give
up your right to sue any other entity that may also be responsible for injuries to you related to the Relevant Conduct.
You will also not be giving up your right to sue JPMC for the time period prior to January 1, 1998 or after December 31,
2006. You will, however, give up your right to sue JPMC for the 1998-2006 time period, which means you could not
sue JPMC for certain claims that are currently being pursued on your behalf in the In re Municipal Derivatives Antitrust
Litigation, described in the next section. In connection with the In re Municipal Derivatives Antitrust Litigation, Class
Counsel has submitted comments to the proposed States' Settlement with Bank of America stating their concerns
about participation in its proposed distribution. In determining whether to participate in the States' Settlement with
JPMC, prospective recipients should consult counsel. The views of Class Counsel and the Attorneys General in this
regard may be obtained by communicating with them directly. Contact information for them is provided in question 21
of the enclosed Question and Answer Pamphlet and Addendum B to that pamphlet.
Any variance between this Notice Letter and the Settlement Agreement will be controlled by the Settlement
Agreement.
Related Pending Civil Actions
Beginning in March 2008, JPMC was named as a defendant along with numerous other financial institutions
and brokers in civil suits filed in state and federal courts in New York, the District of Columbia, California, and West
Virginia. To date, 30 such actions have been filed, which name JPMC as a defendant. The named plaintiffs in these
complaints are governmental, quasi -governmental, and not -for -profit entities that issue and/or receive the proceeds of
municipal bonds and invest those bond proceeds in Municipal Bond Derivatives provided by the defendants. Some of
the cases have been brought as putative class actions on behalf of these entities nationwide, and others as individual
actions.
A number of these lawsuits bring class actions on behalf of a putative class of entities that entered into
Municipal Bond Derivatives transactions with any provider or broker (not just JPMC) at any point in time from 1992
through the present. Thus, you might be both a member of a putative class and also eligible to receive restitution
under this Settlement.
All of the cases have now been transferred to the U.S. District Court for the Southern District of New York and
consolidated for pretrial proceedings in a single litigation entitled In re Municipal Derivatives Antitrust Litigation, MDL
No. 1950, Master Civil Action No. 08-2516 (S.D.N.Y.). The complaints allege that the defendants, including JPMC,
conspired to violate federal and state antitrust laws by allocating customers, and fixing or stabilizing rates of return on
certain Municipal Bond Derivatives from 1992 to the present-
2
RELEASE
1. In consideration of the receipt by Releasor of $258,671.20 relating to the KO PSA SWAP (approximate trade date
04/11/2002); TERMINATION BY UNWIND (approximate trade date 06/30/2005), payment of which is made by
JPMC in accordance with the terms of the Settlement Agreement, Releasor hereby releases Releasee from all civil
claims, counterclaims, cross -claims, set -offs, causes of action of any type (whether common law, equitable, statutory,
regulatory or administrative, class, individual or otherwise in nature, and whether reduced to judgment, liquidated,
unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, secured or unsecured) demands, disputes,
damages, restitution, whenever incurred, and liabilities (including joint and several) of any nature whatsoever,
including without limitation, costs, fines, debts, expenses, penalties and attorneys fees, known or unknown, that it has
against the Releasee arising from the Relevant Conduct in relation to the marketing, sale or placement of Municipal
Bond Derivatives, including any claims that have been or could be asserted In re Municipal Derivatives Antitrust
Litigation, MDL No. 1950, Master Docket No. 08-2156, any actions pending in the United States District Court for the
Southern District of New York captioned In re Municipal Derivatives Antitrust Litigation, or any related actions filed in or
transferred to the United States District Court for the Southern District of New York that are coordinated with or
consolidated into the preceding Civil Action docket.
2. In the event that the total payment referred to in Paragraph 1 is not made for any reason, then this Release shall be
null and void, provided that any payments received by Releasor shall be credited to Releasee in connection with any
claims that (i) Releasor may assert against Releasee; (ii) that are asserted against Releasee on behalf of Releasor by
a class of which Releasor is a member; or (iii) that are asserted by any third party against Releasee as to which
Releasee may assert a setoff under any applicable law.
3. The Releasor intends by this Release to settle with and release only Releasee and does not intend this Release, or
any part hereof or any other aspect of the settlement or the releases, to extend to, to release or otherwise to affect in
any way any rights that the Releasor has or may have against any other parry or entity whatsoever, other than
Releasee.
4. Releasor hereby waives the provisions of California Civil Code section 1542, which provides: "A general release does
not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of executing
the release, which if known by him or her must have materially affected his or her settlement with the debtor." This
provision shall not be deemed to turn a specific release into a general release.
5. The Releasor represents and warrants that the released claims have not been sold, assigned or hypothecated, in
whole or in p
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JPMC Muni Bond Derivative Settlement
Go GCG
Claims Administrator
P.O. Box 9864
Dublin, OH 43017-5764
(877) 311-1632
ioeir'ri11111o11111Ae11111e1111
CITY OF LUBBOCK
TOM MARTIN, MAYOR
162513TH ST
LUBBOCK, TX 79401
CMB
111111111111111111111111111 IN 1111111111111111111
Claim No: CMB01000457
RELEASE BY PARTICIPATING COUNTERPARTIES
This release executed this day of 20 , by the Releasor (as defined below) in favor of the
Releasee (as defined below).
DEFINITIONS
A. "Releasor" shall mean CITY OF LUBBOCK, TX and any of its divisions, affiliates, subsidiaries, groups, associates,
general or limited partners or partnerships, predecessors, successors or assigns, including, without limitation, any of
their respective present officers, trustees, employees, agents, attorneys, representatives and shareholders, affiliates,
associates, general or limited partners or partnerships, heirs, executors, administrators, predecessors, successors,
assigns or insurers acting on behalf of Releasor.
B. "Releasee" refers to JPMorgan Chase & Co., and all of its successors, predecessors, assigns and their subsidiaries,
divisions, groups, affiliates and partnerships, including without limitation, any of their respective past or current officers,
directors, and employees (collectively, "JPMC').
C. "Relevant Conduct" shall mean, except as provided below, JPMC engaging in any of the following conduct from
January 1, 1998 through December 31, 2006, whether by itself or in concert with Providers and Brokers: (i) rigging
bids or fixing the prices or other terms and conditions of any Municipal Bond Derivatives; (ii) agreeing not to bid for any
Municipal Bond Derivatives; or (iii) engaging in any other anticompetitive, deceptive, unfair or fraudulent conduct
relating to any Municipal Bond Derivatives including, but not limited to, misrepresenting or omitting material facts
whose primary purpose is to prevent the discovery of the anti -competitive conduct. Notwithstanding the foregoing,
Relevant Conduct does not include conduct related to attempts to manipulate underlying interest rates used in the
pricing of Municipal Bond Derivatives.
D. "Municipal Bond Derivatives" shall mean: (i) contracts involving the reinvestment of the proceeds of tax-exempt bond
issues and Qualified Zone Academy Bonds, or bonds issued by or on behalf of any governmental or
quasi -governmental or non-profit entity in the United States of America, including but not limited to, states, cities,
towns, counties, villages, parishes, school districts, clubs, or various economic development, redevelopment,
financing, lottery, parking, housing, educational, medical, religious, public safety, building, water, sewer, hospital,
transportation, public works, waste management, environmental, port, park, airport, telecommunications and power
authorities, corporation or boards; and (ii) transactions involving the management or transfer of the interest rate risk
associated with the bonds or bond issues described above including, but not limited to, guaranteed investment
contracts, forward supply, purchase, or delivery agreements, repurchase agreements, swaps, options and swaptions.
Notwithstanding the foregoing, Municipal Bond Derivatives does not include (i) contracts to underwrite the issuance of
municipal bonds; (ii) credit default products, such as credit default swaps and credit default options; (iii) auction -rate
securities; (iv) inter- dealer swaps; (v) swaps, or other agreements between providers to hedge, manage or otherwise
share or transfer their risk on a Municipal Bond Derivative except to the extent used to facilitate any improper
undisclosed payments to brokers or the rigging of bids for the reinvestment or management of bond proceeds.
E. "Covered Derivatives" shall mean Municipal Bond Derivatives that meet the criteria set forth in Attachment A to the
Settlement Agreement.
F. "Settlement Agreement" shall mean the Settlement Agreement between JPMorgan Chase & Co. and the Attorneys
General of the States and Commonwealths of Alabama, California, Colorado, Connecticut, District of Columbia,
Florida, Idaho, Illinois, Kansas, Maryland, Massachusetts, Michigan, Missouri, Montana, Nevada, New Jersey, New
York, North Carolina, Ohio, Oregon, Pennsylvania, South Carolina, Texas, Tennessee, Wisconsin, dated July 7, 2011.
G. "Effective Date" shall mean the Effective Date of the Settlement Aqreement.
In order to participate in the Settlement, you will be required to sign the Release, which gives up your right to
sue JPMC for certain claims for damages, including claims being brought in the In re Municipal Derivatives Antitrust
Litigation or in any suit against JPMC you bring on your own. If you choose to participate in this Settlement, you will
also be giving up your right to participate in JPMC's settlement of /n re Municipal Derivatives Antitrust Litigation.
Lead Counsel in In re Municipal Derivatives Antitrust Litigation have reached a settlement with JPMC
pursuant to which JPMC has agreed to pay a settlement amount of up to $44,575,000 dollars for the benefit of
a proposed settlement class. That settlement has not yet been approved by the Court.
In that case, the proposed settlement class includes all state, local and municipal government entities,
independent government agencies, quasi -government, non-profit and private entities that (i) purchased by negotiation,
competitive bidding or auction municipal derivative transactions directly from JPMC, Wachovia Bank, N.A., Wells Fargo
& Company, Bank of America, N.A., Bear, Stearns & Co., Inc., Morgan Stanley, National Westminster Bank Plc, Natixis
Funding Corp., Piper Jaffrey & Co., Societe Generale SA, UBS AG, AIG Financial Products Corp., SunAmerica Life
Assurance Co., Financial Security Assurance Holdings, Ltd., Financial Security Assurance, Inc., Trinity Funding Co.
LLC, GE Funding Capital Market Services, Inc., Lehman Brothers, MG Financial Products Corp., XL Capital Ltd., XL
Asset Funding Co. I LLC or XL Life Assurance & Annuity, Inc., or other providers that could have been named as
defendants or co-conspirators or (ii) purchased by negotiation, competitive bidding or auction municipal derivative
transactions brokered by Natixis Funding Corp., f/k/a IXIS Funding Corp., and before that, f/k/a CDC Funding Corp.,
Investment Management Advisory Group, Inc., CDR Financial Products, Winters & Co. Advisors, LLC, George K.
Baum & Co., Sound Capital Management, Inc., Piper Jaffray & Co., Feld Winters Financial LLC, First Southwest
Company, Kinsell Newcomb & De Dios Inc., Mesirow Financial, Morgan Keegan & Co., Inc., PackerKiss Securities,
Inc., or other brokers that could have been named as defendants or co-conspirators at any time from January 1, 1992
through August 18, 2011, in the United States and its territories or for delivery in the United States or its territories.'
As with any class action in court, any settlement in the /n re Municipal Derivatives Antitrust Litigation would
have to be approved by a judge. Your allocated share of any recovery resulting from the class action settlement,
should it be approved by the court, or from the resolution of litigation you institute, may be greater or less than your
eligible share under this Settlement. If you participate in this Settlement with JPMC, you will not be eligible to make a
claim under the class settlement with JPMC.
This Settlement is different from a class action settlement. First, the Settlement is pursuant to the sovereign
authority of the 25 State Attorneys General who entered into the Settlement Agreement. Second, the Settlement is an
out -of -court settlement and thus has not been subject to preliminary and final court approval proceedings, a fairness
hearing or objections.
The accompanying Question and Answer Pamphlet contains a more detailed explanation of the civil actions
pending in the Southern District of New York in the In re Municipal Derivatives Antitrust Litigation and the contact
information for interim class counsel in that case.
1 A copy of the Settlement Agreement between JPMC and the named class plaintiffs in In re Municipal Derivatives Antitrust
Litigation, MDL No. 1950, dated April 18, 2012, is available from Lead Counsel, or htta://r)acer.loain.uscourts.gov.
3
Instructions on How You May Receive Payment
To receive a payment from the Fund, you must timely submit to the Claims Administrator the enclosed (1)
Election to Participate and (2) Release. You should carefully read through the materials and be sure to submit both the
Election to Participate and the executed Release. Failure to submit both forms in accordance with the instructions and
as set forth in the Settlement Agreement may result in the rejection of your claim.
The documents must be postmarked NO LATER THAN AUGUST 23, 2012. They should be returned to the
following address in the enclosed self-addressed postage prepaid envelope:
JPMC Muni Bond Derivative Settlement
c/o GCG
Claims Administrator
P.O. Box 9684
Dublin, OH 43017-5764
Election to Not Participate or Otherwise Not Respond
If you elect not to participate or otherwise do not respond to this Notice Letter, the Settlement Agreement shall
have no effect on the claims or causes of action for damages, disgorgement, restitution or any other relief that you may
have against JPMC for the Relevant Conduct, including any right you might have to participate in any settlement of any
claims in the pending actions or to pursue your own independent action. It is recommended that you consult with an
attorney for legal advice as to your options.
Additional Information
For more information please refer to the Question and Answer Pamphlet enclosed with this Notice Letter. You
may also:
• Visit the website: www.stateAGmunisettlement.com
• Write the Claims Administrator, GCG at:
JPMC Muni Bond Derivative Settlement
c/o GCG
Claims Administrator
P.O. Box 9684
Dublin, OH 43017-5764
Information as to how to contact the private class counsel in the In re Municipal Derivatives Antitrust Litigation is
contained in the Question and Answer Pamphlet (at Question 21).
Sincerely,
The Claims Administrator
4
JPMC Muni Bond Derivative Settlement
Go GCG
Claims Administrator
P.O. Box 9864
Dublin, OH 43017-5764
(877) 311-1632
�eoirii'n1111111111un
CITY OF LUBBOCK
TOM MARTIN, MAYOR
1625 13TH ST
LUBBOCK, TX 79401
ELECTION TO PARTICIPATE IN
SETTLEMENT WITH JIP MORGAN CHASE & CO.
CMB
Claim No: CMB01000457
CITY OF LUBBOCK, TX, hereby elects to participate in the Settlement Agreement Among the Attorneys General of the
States and Commonwealths of Alabama, California, Colorado, Connecticut, District of Columbia, Florida, Idaho, Illinois,
Kansas, Maryland, Massachusetts, Michigan, Missouri, Montana, Nevada, New Jersey, New York, North Carolina, Ohio,
Oregon, Pennsylvania, South Carolina, Texas, Tennessee and Wisconsin and JP Morgan Chase & Co., dated July 7,
2011.
By signing below, I am confirming that: (1) 1 have authority to act on behalf of the Participating Counterparty; (2) the
Participating Counterparty was the counterparty to each of the Covered Derivatives listed in the Release; and (3) the
Participating Counterparty has not assigned, sold, or otherwise transferred its rights to any of the Covered Derivatives (or
did not assign, sell, or transfer its rights prior to termination of any of the transactions).
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Question and Answer Pamphlet
THESE QUESTIONS AND ANSWERS ARE NOT LEGAL ADVICE. They are provided for informational
purposes only. Actual legal advice can only be provided after consultation with an attorney in your
jurisdiction.
1. What is the purpose of this Notice Packet?
The purpose of this Notice Packet is to inform you of a $65.5 million settlement fund established pursuant to
an out -of -court settlement between JP Morgan Chase & Co. ("JPMC") and 25 States Attorneys General to
resolve matters more specifically explained in "An Agreement Among the Attorneys General of the States
and Commonwealths of Alabama, California, Colorado, Connecticut, District of Columbia, Florida, Idaho,
Illinois, Kansas, Maryland, Massachusetts, Michigan, Missouri, Montana, Nevada, New Jersey, New York,
North Carolina, Ohio, Oregon, Pennsylvania, South Carolina, Texas, Tennessee and Wisconsin and
JP Morgan Chase & Co." dated July 7, 2011 (referred to herein as either the "Settlement Agreement" or
the "Settlement"). A full copy of the Settlement Agreement can be obtained by visiting
www.stateAGmunisettlement.com. This Notice Packet provides an overview of the Settlement Agreement
along with your rights and steps you must take in order to receive your share of the Fund as an Eligible
Counterparty.
2. Why did I receive this Notice Packet?
The purpose of this Notice Packet is to inform you that 25 State Attorneys General and JPMC have entered
into an out -of -court settlement to distribute a total of $65.5 million to affected entities in 50 states and select
U.S. territories as described in the Settlement Agreement. You have received this Notice Packet because
you have been identified as an affected -entity ("Eligible Counterpart)(') who may elect to participate in this
Settlement as indicated in this Notice Packet. Based on the investigation conducted by the Attorneys
General, with cooperation from JPMC, the Attorneys General allege that the listed Municipal Bond
Derivative you engaged in with JPMC was impacted by the Relevant Conduct outlined in the Settlement
Agreement.
3. What is the Relevant Conduct?
Generally, the Relevant Conduct means engaging in anticompetitive conduct and/or unfair trade practices
relating to Municipal Bond Derivatives between January 1, 1998 through December 31, 2006.
The State Attorneys General have alleged that: (i) certain JPMC employees participated in an -illegal
scheme -with -brokers and other providers with whom they had relationships to put their mutual financial
interests ahead of those of the Municipal Bond Derivative clients they represented; (ii) JPMC's employees'
participation in the scheme began at least as early as 2001 and continued through at least 2005; (iii) JPMC
and other providers and brokers were principal players in the conduct and -obtained unjust profits as a
result; and (iv) the wrongful conduct caused Issuers throughout the United States to be paid artificially
suppressed rates or yields -on Municipal Bond Derivative transactions that were the subject of the conduct.
JPMC was identified as a firm which engaged in unlawful conduct through investigations by the Antitrust
Division of the United States Department of Justice, the Securities and Exchange Commission, the Federal
Reserve Bank, the Office of the Comptroller of the Currency and the Attorneys General. The Settlement
Agreement with JPMC is part of a broad and ongoing three-year investigation of the municipal bond
derivatives industry by the Attorneys General. As part of its obligations under the Settlement Agreement,
JPMC has agreed to continue to cooperate with the Attorneys General's ongoing investigation.
The Settlement Agreement contains a more detailed explanation of the Relevant Conduct. JPMC has not
admitted the allegations of the Relevant Conduct. A full copy of the Settlement Agreement can be obtained
by visiting www.stateAGmunisettlement.com.
4. What is an "Eligible Counterparty"?
An Eligible Counterparty means Municipal Bond Derivatives Counterparties that entered into one or more
Covered Derivatives with JPMC from January 1, 2001 to December 31, 2005.
5. What is a "Municipal Bond Derivatives Counterparty"?
A Municipal Bond Derivatives Counterparty is an entity that entered into one or more Municipal Bond
Derivatives with JPMC, but does not include Providers, Brokers, other financial institutions or any for profit
entities.
6. What is a "Covered Derivative"?
A Covered Derivative is a Municipal Bond Derivative that was (1) awarded through a competitive bidding
process or a negotiated process where the provider is JPMC; (2) entered between (i) January 1, 2001 and
December 31, 2004 inclusive for Municipal Bond Derivatives awarded through a competitive bidding
process; or (ii) January 1, 2001 and December 31, 2005, inclusive for Municipal Bond Derivatives awarded
through other than a competitive bidding process; and (3) identified by the Attorneys General as a
transaction they believe was impacted by the Relevant Conduct, based upon evidence developed by the
Investigation. Based on the evidence developed through the Attorneys General's investigation, the
Attorneys General believe that: (a) participation by specific JPMC marketers in the illegal conduct was
primarily carried out during the period January 1, 2001 through December 31, 2005; and (b) JPMC
marketers engaged in the Relevant Conduct with only certain providers and brokers. Therefore, the
Settlement Agreement provides for compensation to Eligible Counterparties only for transactions during the
period January 1, 2001 through December 31, 2005. Covered Derivatives deemed to have been impacted
are those transactions in which specific JPMC marketers or specific brokers participated.
7. What are the benefits of the Settlement?
JPMC paid a total of $65.5 million into a fund that will be used to make restitution to certain Municipal Bond
Derivative Counterparties, including you. The Settlement Agreement provides a simple process for you to
receive your share of the settlement fund specified in this Notice Packet.
To receive a payment pursuant to this Settlement all you need to do is return the Election to Participate and
the Release. No other documentation is required.
8. What do I give up if I choose to participate in the Settlement?
In order to participate in this Settlement, you will be required to sign the Release included in the packet. By
signing the Release, you would be giving up your right to sue JPMC for certain claims for damages against
JPMC in the civil class actions in the In re Municipal Derivatives Antitrust Litigation (described further below
in Question 9) or in any suit against JPMC you bring on your own. You will also be giving up your right to
participate in JPMC's settlement in the In re Municipal Derivatives Antitrust Litigation.
The named plaintiffs in In re Municipal Derivatives Antitrust Litigation have reached a settlement with JPMC
pursuant to which JPMC has agreed to pay a settlement amount of up to $44,575,000 for the benefit of a
proposed settlement class. That settlement has not yet been approved by the court.
In that case, the proposed settlement class includes all state, local and municipal government entities,
independent government agencies, quasi -government, non-profit and private entities that (i) purchased by
negotiation, competitive bidding or auction municipal derivative transactions directly from JPMC, Wachovia
Bank, N.A., Wells Fargo & Company, Bank of America, N.A., Bear, Stearns & Co., Inc., Morgan Stanley,
National Westminster Bank Plc, Natixis Funding Corp., Piper Jaffrey & Co., Societe Generale SA, UBS AG,
AIG Financial Products Corp., SunAmerica Life Assurance Co., Financial Security Assurance Holdings,
Ltd., Financial Security Assurance, Inc., Trinity Funding Co. LLC, GE Funding Capital Market Services, Inc.,
Lehman Brothers, MG Financial Products Corp., XL Capital Ltd., XL Asset Funding Co. I LLC or XL Life
Assurance & Annuity, Inc., or other providers that could have been named as defendants or co-conspirators
or (ii) purchased by negotiation, competitive bidding or auction municipal derivative transactions brokered
by Natixis Funding Corp., f/k/a IXIS Funding Corp., and before that, f/k/a CDC Funding Corp., Investment
Management Advisory Group, Inc., CDR Financial Products, Winters & Co. Advisors, LLC, George K.
Baum & Co., Sound Capital Management, Inc., Piper Jaffray & Co., Feld Winters Financial LLC, First
Southwest Company, Kinsell Newcomb & De Dios Inc., Mesirow Financial, Morgan Keegan & Co., Inc.,
PackerKiss Securities, Inc., or other brokers that could have been named as defendants or co-conspirators
at any time from January 1, 1992 through August 18, 2011, in the United States and its territories or for
delivery in the United States or its territories.'
As with any class action in court, any settlement in the In re Municipal Derivatives Antitrust Litigation would
have to be approved by a judge. Your allocated share of any recovery resulting from the class action
settlement, should it be approved by the court, or from the resolution of litigation you institute, may be
greater or less than your eligible share under this Settlement. If you participate in this Settlement with
JPMC, you will not be eligible to make a claim under the class settlement with JPMC.
In determining whether you should participate in the Settlement, it is recommended that you consult with
counsel of your own choosing. THESE QUESTIONS AND ANSWERS ARE NOT LEGAL ADVICE. They
are provided for informational purposes only. Actual legal advice can only be provided after consultation
with a licensed attorney.
9. What are the details of the related pending civil actions in the In re Municipal Derivatives
Antitrust Litigation?
In March 2008, two private law firms (Hausfeld LLP and Boies Schiller & Flexner, LLP) filed the first case
in the country against JPMC, in federal court based on the Relevant Conduct, which is described in
Question 3 above. Other attorneys filed suits across the country as well.
The filed cases were consolidated in the Southern District of New York (In re Municipal Derivatives Antitrust
Litigation, MDL No. 1950, Master Civil Action No. 08-2516), and Judge Victor Marrero was selected to
preside over the cases. Judge Marrero chose three private law firms - Hausfeld LLP, Boies Schiller &
Flexner, LLP, and Susman Godfrey - as interim lead class counsel ("Lead Counsel") to represent a class of
entities allegedly injured by the Relevant Conduct. Having received additional information from the leniency
applicant, Bank of America, Lead Counsel filed a Second Amended Complaint that describes in detail the
illegal scheme Lead Counsel alleges took place. It alleges that defendants, including JPMC, conspired to
violate federal and state antitrust laws by allocating customers and fixing or stabilizing rates of return on
certain municipal derivatives from 1992 to the present. The lawsuits seek unspecified damages, restitution,
disgorgement and such other relief as may be granted by the court.
The claims in the In re Municipal Derivatives Antitrust Litigation include claims similar to the claims being
settled by the Settlement Agreement but also include claims (1) for the entire period of 1992 to the present;
(2) claims based on derivatives that JPMC bid on but did not win; and (3) claims for triple damages.
As of this date, the named plaintiffs in In re Municipal Derivatives Antitrust Litigation have reached a
settlement with JPMC, which the court has not yet approved. Your allocated share of any recovery resulting
from that settlement, should it be approved by the Court, could be greater or less than your eligible share
under the Settlement. If you participate in this Settlement you will not be eligible to participate in JPMC's
settlement of In re Municipal Derivatives Antitrust Litigation.
' A copy of the Settlement Agreement between JPMC and the named class plaintiffs in In re Municipal
Derivatives Antitrust Litigation, MDL No. 1950, dated April 18, 2012, is available from Lead Counsel, or
hftp://i)aoer.login.uscourts.gov.
Addendum A to this Pamphlet contains a listing of the civil actions pending in the In re Municipal Derivatives
Antitrust Litigation. A listing is also included at www.stateAGmunisettlement.com. The contact information
for Lead Counsel is provided in Question 21 below.
10. What are the differences between this Settlement and the settlement in the class action?
The entire $65.5 million in this Fund has been allocated to Eligible Counterparties. In the class action
settlement, up to $44.575 million will be used to make payments to class members, for notice and
administration costs, taxes and expenses, attorneys' fees and costs, and distribution costs. Lead Counsel
have not yet proposed a plan for distributing up to $44.575 million or determined what part of the $44.575
million will be allocated to make payments to class members.
11. What State Attorneys General are parties to the Settlement?
The Attorneys General of Alabama, California, Colorado, Connecticut, District of Columbia, Florida, Idaho,
Illinois, Kansas, Maryland, Massachusetts, Michigan, Missouri, Montana, Nevada, New Jersey, New York,
North Carolina, Ohio, Oregon, Pennsylvania, South Carolina, Tennessee, Texas, and Wisconsin have
elected to participate in the Settlement Agreement. Relevant contact information for these Attorneys
General is available at www.stateAGmunisettlement.com.
Regardless of whether your State Attorney General is a party to the Settlement, you can choose whether to
participate in the Settlement and release your claim(s) against JPMC. It is your decision.
12. If I reside in a State where the Attorney General is not a party to the Settlement Agreement
can I still participate?
Yes, you can participate because you are an Eligible Counterparty. The fact that the Attorney General in
your State is not a party to the Settlement Agreement does not affect your ability to claim from the Fund.
You should be guided by the Notice Packet and follow the instructions for filing an Election to Participate
and Release.
13. How do I participate?
In order to participate and receive payment from the Fund, you must timely submit both the (1) Election to
Participate and (2) the Release. Your Release and Election to Participate must be postmarked no later than
45 days from the date of the letter accompanying this Notice Packet. No other documentation is required.
14. Do I have to participate?
No. If you decide you do not want to participate in this Settlement you do not have to take any affirmative
action. That is, if you do not return the Election to Participate and Release you will be excluded from the
Settlement. Also, you will retain your right to bring claims against JPMC for the Relevant Conduct, either
through your own litigation or the civil class actions.
15. What is my share of the Fund?
The total amount of your distribution is set forth on page 1 of the Notice under the heading "Your Share."
16. How was my share calculated?
Your share was based on a formula developed by the Attorneys General with the assistance of an
independent economic expert hired by the Attorneys General. The Settlement Agreement provides that the
Attorneys General have the right to adopt a formula they deem appropriate for payments from the
settlement fund. The Attorneys General's economic expert was retained early in the Attorneys General's
investigation to review and analyze data obtained by the Attorneys General as part of their investigation,
and to assist in estimating alleged overcharges caused by the relevant conduct. Once the Attorneys
General and JPMC had reached agreement on the amount of restitution (which included the Attorneys
General's estimate of the overcharge plus interest) that JPMC would pay into the settlement fund ($65.5
million), the Attorneys General asked their economic expert to develop a formula and plan to allocate the
settlement fund. The entire $65.5 million will be available for distribution to Eligible Counterparties.
Your share of the settlement fund will be determined using an overcharge methodology established by the
Attorneys General that takes into account the estimated overcharge percentage assigned for the general
type(s) of Covered Derivative(s) you entered into with JPMC (e.g., interest rate swap, forward purchase
agreement, guaranteed investment contract, etc.) in a particular time period. It defines dollar overcharge
(which is used in estimating the overcharge percentage) as the difference between (1) the amount of
estimated profit attributed to your Covered Derivative(s), and (2) the estimated profit JPMC would have
earned absent the Relevant Conduct (otherwise known as the "But -for -Profit"). Your share equals the
percentage that your estimated dollar overcharge is to the total overcharge for all Eligible Counterparties
(the "Share of Damages") multiplied by the settlement fund. Thus, for example and only for purposes of
illustration, if the estimated dollar overcharge represented .03% of the total overcharge for all Eligible
Counterparties, it would be multiplied by $65.5 million and your share of the settlement fund would be
$19,650 (the "Fund Share"). If you entered into more than one Covered Derivative with JPMC, then your
total share of the settlement fund will be the sum of the Fund Shares for all such Covered Derivatives you
entered into with JPMC.
Because this is a nationwide recovery, the same formula was applied to all Eligible Counterparties for the
type(s) of Covered Derivatives they purchased, regardless of the state in which they reside. There will be
no deductions whatsoever from the Fund for attorneys' fees, expenses or administrative costs. For
additional information, see Question 19 below.
By participating in this Settlement, you are giving up your right to pursue a different formula for recovery
against JPMC. You could pursue a different formula only if you decided not to participate in the Settlement
and instead brought your own action or participated in the In re Municipal Derivatives Antitrust Litigation
class action settlement with JPMC.
17. What happens to any money left in the Fund after all participating Eligible Counterparties
are paid?
If any money remains in the Fund after all Eligible Counterparties who want to participate are paid their full
allocation, the Fund can be used to pay other claims against JPMC by Municipal Bond Derivative
Counterparties (including claims asserted in the civil class actions) arising from the same Relevant Conduct
as is the subject of the Settlement Agreement. In the event any money remains after all eligible claims have
been paid, the remaining funds may be used by the Attorneys General for additional distribution to Eligible
Counterparties that participated in the Attorneys General Settlement, for the antitrust training of deputy and
assistant attorneys general, or as otherwise directed by the Attorneys General. Under no circumstances
will any money be returned to JPMC.
18. What are the tax ramifications if I elect to participate and are there any ramifications for
holders of tax exempt bonds which I issued or that were issued in connection with my Municipal
Bond Derivative(s)?
JPMC entered into a settlement agreement with the Internal Revenue Service ("IRS") which required JPMC
to make payments to the IRS with respect to JPMC's Relevant Conduct in connection with your Municipal
Bond Derivative(s) that are the subject of the Settlement Agreement.
Under its settlement with the IRS, for purposes of determining your compliance with the arbitrage
requirements of Section 148 of the Internal Revenue Code, the Municipal Bond Derivative(s) that you
entered into with JPMC during the period 1997 through 2006 are deemed to have been entered into on
terms which represented the fair market value of such Municipal Bond Derivative(s). Moreover, for
purposes of Sections 103 and 141 through 150 of the Internal Revenue Code, any settlement payments
received from JPMC by affected issuers are not required to be included in the gross proceeds of the related
bond issue.
If you have further questions on the tax ramifications of this settlement, you should contact your tax advisor.
19. Do I have to pay attorney fees or administrative costs?
No. Under the Settlement Agreement, JPMC is responsible for paying all of the costs of administering the
Settlement. In addition, you do not need to pay any attorney fees to the State Attorneys Generals in order
to participate in this Settlement.
In addition to the $65.5 million settlement fund, JPMC has made a separate Additional Payment of
$6 million to an escrow fund that will be used to reimburse fees and expenses in connection with the
Attorneys General's investigation, and for other purposes that the Attorneys General deem appropriate,
consistent with state laws. JPMC has also paid a $3.5 million civil penalty to the Attorneys General.
20. Does the Settlement Agreement have any provisions relating to conduct by JPMC?
Yes. Pursuant to the Settlement Agreement, JPMC has agreed that its officers, managers, agents,
employees and any other person or company acting on its behalf or at its direction, will not directly or
indirectly, maintain, solicit, suggest, advocate, discuss or cant' out any combination, conspiracy, agreement,
understanding, plan or program with any actual or potential competitor, financial advisor, bidding agent or
broker to (a) submit courtesy or otherwise non-competitive or intentionally losing bids for Municipal Bond
Derivatives, (b) refrain from bidding on or negotiating for Municipal Bond Derivatives, (c) unlawfully or
fraudulently coordinate the preparation, submission, content, price and other terms of competitors' bids for
competitively -bid Municipal Bond Derivatives or (d) engage in the Relevant Conduct as defined above.
JPMC, its directors, officers, managers, agents, employees and any other person or company acting on its
behalf or at its direction, also agreed that they will not, in conjunction with the marketing, sale or placement
of Municipal Bond Derivatives, make misrepresentations or omit material facts to potential counterparties,
their agents, brokers or advisors.
21. Whom can I contact if 1 have additional questions?
You are free to consult with counsel of your own choosing
In addition, with respect to questions about the Settlement Agreement, you or your counsel may contact
The Garden City Group, Inc.("GCG"), the independent Claims Administrator, by writing to:
JPMC Muni Bond Derivative Settlement
c/o GCG
Claims Administrator
P.O. Box 9864
Dublin, OH 43017-5764
or
JPMCQuestions@stateAGmuniseftlement.com
You or your counsel may also contact your Attorney General's Office. If you would like to speak to
your Attorney General but the State in which you are located does not have a participating Attorney
General, we ask that you e-mail us at JPMCQuestions@stateAGmunisettlement.com and your question
will be forwarded to State Attorneys General's Claims Representative, Joseph S. Betsko,
Deputy Attorney General with the Commonwealth of Pennsylvania. Please see Addendum B or visit
www.stateAGmunisettlement.com for a complete listing of the contact information for the participating State
Attorneys General.
With respect to questions about the civil class actions in the In re Municipal Derivatives Antitrust Litigation,
you or your counsel may contact Lead Counsel:
Michael Hausfeld
Hausfeld LLP
1700 K Street, NW, Suite 650
Washington, D.C. 20008
Tel: (202) 540-7200
Email: munibonds@hausfeldllp.com
Or visit: www.hausfeldlip.com
If you are in California, you or your counsel may also contact the lawyers who represent the putative
California statewide class:
Sylvia M. Sokol
Moscone Emblidge & Sater LLP
220 Montgomery Street, Suite 2100
San Francisco, CA 94104
Tel: (415) 992-4355
Email: Sokol@meslip.com
Eric Fastiff
Lieff Cabraser Heimann & Bernstein, LLP
275 Battery Street, 29th Floor
San Francisco, CA 94111-3339
Tel: (415) 956-1000
Email: efastiff@lchb.com
ADDENDUM A:
JPMC Municipal Bond Derivatives Notice Packet
IN RE MUNICIPAL DERIVATIVES ANTITRUST LITIG.
CIVIL LITIGATION
Case Caption
Named Plaintift(s)
Hinds County, MS v. Wachovia Bank N.A.et al.
City of Baltimore, MD
Univ. of Miss. Med. Ctr.
This is the lead class action in the consolidated litigation under
Univ. of South. Miss.
Master Docket No. 08-2516 (S.D.N.Y.) & MDL No. 1950
Miss. Dept Transportation
Univ. of Miss.
Central Bucks Sch. Dist
Bucks County Water & Sewer Auth.
Oakland v. AIG Fin. Prods. Coro., et al, (08-6340 S.D.N.Y.)
City of Oakland, CA
Alameda v. AIG Fin. Prods. Corp., et al. (08-7034 S.D. N.Y.)
County of Alameda, CA
Fresno v. AIG Fin Prods. Corp.. et al. (08-7355 S.D.N.Y.)
City of Fresno, CA
Fresno County Fin. Auth. v. AIG Fin. Prods. Corp., et al. (09-1199
Fresno County Financing Auth.
S.D.N.Y.)
East Bay Delta Housing & Finance Agency v. Bank of America.
East Bay Delta Housing & Finance Agency
N.A. et al. S.D.N.Y. 11-5796
West Virginia v. Bank of America. N.A. et al. (10-769 S.D. N.Y.)
State of West Virginia by and through the Attorney General Darrell
V. McGraw, Jr.
Los Angeles v. Bank of America. N.A. et al. (08-10351 S. D. N.Y.)
City of Los Angeles, CA
Stockton v. Bank of America. N.A. et al. (08-10352 S.D.N.Y.)
City of Stockton, CA
San Diego v. Bank of America. N.A. et al. (09-1195 S.D.N.Y.)
County of San Diego, CA
San Mateo v. Bank of America. N.A. et al. (09-1196 S.D.N.Y.)
County of San Mateo, CA
Contra Costa v. Bank of America. N.A. et al. (09-1197 S.D.N.Y.)
County of Contra Costa, CA
Sacramento Mun. Ufil Dist v. Bank of America. N.A. et al. (09-
Sacramento Municipal Utility District (SMUD)
10103 S. D.N.Y.)
Riverside v. Bank of America N.A et al. (09-10102 S.D. N.Y.)
City of Riverside
Tulare v. Bank of America. N A. et al. (10-628 S. D.N.Y.)
County of Tulare, CA
Sacramento Suburban Water Dist v. Bank of America. N.A. et al.
Sacramento Suburban Water District
(10-629 S.D. N.Y.)
City of Stockton Redev. Agency & Pub. Fin. Auth. v. Bank of
City of Stockton Redevelopment Agency & Public Financing
America. N.A. et al. (10-6W S.D.N.Y.)
Authority
L.A World Airports v. Bank of America. N.A. et al. (10-627
Los Angeles World Airports
S.D.N.Y.)
Redevel. Agency of the City and County of San Francisco v. Bank of
Redevelopment Agency of the City and County of San Francisco
America. N.A. eta]. (10-4987 S.D. N.Y.)
Richmond v. Bank of America. N.A. et al. (1 G 4989 S.D.N.Y.)
City of Richmond, CA
Redwood City v. Bank of America. N.A. et al. (10-4988 S.D.N.Y.)
Redwood City, CA
East Bay Mun. Util. Dist v. Bank of America. N.A. et al. (10-4990
East Bay Municipal Utility District
S.D.N.Y.)
ADDENDUM A:
JPMC Municipal Bond Derivatives Notice Packet
Case Cspoon
blamed Ptaint#f(s)
San Jose & San Jose Redevel. Agency v. Bank of America. N.A. et
City of San Jose & San Jose Redevelopment Agency
al. (10-4991 S D.N.Y.)
Active Retirement Communty. Inc. d/b/a Jefferson's Ferry v. Bank of
Active Retirement Community, Inc. d/b/a/ Jefferson's Ferry
America. N.A. et al. (10-8273 S.D.N.Y.)
Los Angeles Unified School District v. Bank of America. N.A.. et al.
Los Angeles Unified School Distr. (LAUSD)
(11-361 S.D.N.Y.)
Kendal on Hudson. Inc. v. Bank of America. N.A.. et al. (10.9496
Kendal on Hudson, Inc.
S.D.N.Y.)
Peconic Landing at Southhold. Inc. v. Bank of America. N.A.. et al.
Peconic Landing at Southhold, Inc.
(11-682 S.D.N.Y.)
Utah Housing Corp. v. CDR Fin Prods. Inc.. et al. (11-1019
Utah Housing Corporation
S.D.N.Y.)
ADDENDUM B:
JPMC Municipal Bond Derivatives Notice Packet
State
.Attorney General & Assistant AG
LUTHER STRANGE, Attorney General
James M. Steinwinder, Antitrust Chief
Alabama Attorney General's Office
Alabama
General Civil and Administrative Division
501 Washington Avenue
Montgomery, Alabama 36130
334-353-9171
JSteinwinder(a)-ago.state.al.us
KAMALA D. HARRIS, Attorney General
Natalie S. Manzo, Supervising Deputy Attorney General
California
Office of the Attorney General
300 South Spring Street, Suite 1702
Los Angeles, CA 90013
213-897-2707
Natalie. Manzo(�doi.ca. gov
JOHN W. SUTHERS, Attorney General
Devin M. Laiho, Assistant Attorney General
Colorado
Consumer Protection
1525 Sherman Street, 7th Floor
Denver, Colorado 80203
303-866-5079
devin.laiho(cDstate.co.us
GEORGE JEPSEN, Attorney General
Michael E. Cole, Chief, Antitrust Department
Connecticut
Christopher M. Haddad, Assistant Attorneys General
55 Elm Street, PO Box 120
Hartford, CT 06141-0120
860-808-5040
m ichael.cole(�.ct.4ov
ADDENDUM B:
JPMC Municipal Bond Derivatives Notice Packet
State
Attorney General & AssistantAG
IRVIN B. NATHAN, Attorney General
Bennett Rushkoff
Chief, Public Advocacy Section
District of Columbia
Office of the Attorney General
for the District of Columbia
441 Fourth Street, N.W., Suite 600-S
Washington, DC 20001
202-727-5173
Ben nett. rushkoff(cDdc.gov
PAMELA JO BONDI, Attorney General
Nicholas Weilhammer, Assistant Attorney General
Office of the Attorney General of Florida
Florida
The Capitol
PL-01
Tallahassee, FL 32399-1050
850-414-3921
nicholas.weilhammer(aD-myfloridalegal.com
LAWRENCE G. WASDEN, Attorney General
Brett T. DeLange , Deputy Attorney General
Consumer Protection Division
Idaho
Office of the Attorney General
954 W. Jefferson St., 2nd Floor
P. 0. Box 83720
Boise, Idaho 83 720-001 0
208-334-4114
brett.delange(cDag.idaho.gov
LISA MADIGAN, Attorney General
Jamie Manning, Assistant Attorney General
Illinois
Office of the Illinois Attorney General
100 W. Randolph Street
Chicago, IL 60601
312-814-5470
imanning(cDatg.state. il.us
ADDENDUM B:
JPMC Municipal Bond Derivatives Notice Packet
-State
Attorney General & Assistant AG
TOM MILLER, Attorney General
Layne M. Lindebak, Assistant Attorney General
Iowa Department of Justice
Iowa
Hoover Office Building —Second Floor
1305 East Walnut Street
Des Moines, IA 50319
515-281-7054
Layne. Lindebak aniowa.gov
DEREK SCHMIDT, Attorney General
Lynette R. Bakker, Assistant Attorney General
Kansas
Consumer Protection & Antitrust Division
120 S.W. 10th Avenue, 2nd Floor
Topeka, Kansas 66612-1597
785-296-3751
Ivnette. bakker(cDksag.org
DOUGLAS F. GANSLER, Attorney General
Ellen S. Cooper, Assistant Attorney General
Chief, Antitrust Division
Maryland
John R. Tennis, Assistant Attorney General
Deputy Chief, Antitrust Division
Office of the Attorney General
200 St. Paul Place,19th Floor
Baltimore, Maryland 21202
410-576-6470
itennis(aD-oaq. state. md.us
MARTHA COAKLEY, Attorney General
Mary Freeley
Aaron Lamb
Assistant Attorneys General
Massachusetts
Office of the Attorney General
One Ashburton Place
Boston, MA 02108
617-727-2200
Mary. Freelev(ucD-state. ma. us
Aaron. Lam b(M-state. ma. us
ADDENDUM B:
JPMC Municipal Bond Derivatives Notice Packet
state
Attorney General & Assistant AG
BILL SCHUETTE, Attorney General
D.J. Pasco, Assistant Attorney General
Michigan Department of Attorney General
Michigan
Corporate Oversight Division
525 W. Ottawa Street
Lansing, Michigan 48933
517-373-1160
PascoeDJ(cDmichigan.gov
CHRIS KOSTER, Attorney General
Brianna Lennon, Assistant Attorney General
Missouri Attorney General's Office
Missouri
P.O. Box 899
Jefferson City, MO 65102
573-751-3376
brianna.lennon(cDago.mo.Qov
STEVE BULLOCK, Attorney General
Chuck Munson, Assistant Attorney General
Montana
Office of Consumer Protection
215. N Sanders
Helena, MT 59620-1401
406-444-2026
cmunson(aDmt.gov
CATHERINE CORTEZ MASTO, Attorney General
ERIC WITKOSKI, Consumer Advocate and
Chief Deputy Attorney General
Brian Armstrong, Senior Deputy Attorney General
Nevada
State of Nevada, Office of the Attorney General
Bureau of Consumer Protection
555 E. Washington Ave., Suite 3900
Las Vegas, Nevada 89101
702-486-3420
antitrust(&aa. nv.4ov
ADDENDUM B:
JPMC Municipal Bond Derivatives Notice Packet
state
Attorney General & Assistant AG
JEFFREY S. CHIESA, Attorney General
Brian F. McDonough, Assistant Attorney General
State of New Jersey, Office of the Attorney General
Department of Law and Public Safety
New Jersey
Division of Law
124 Halsey Street, 5th Floor
P.O. Box 45029
Newark, New Jersey 07101
973-648-2500
Brian. McDonough c(a2dol.lps.state.ni.us
ERIC T. SCHNEIDERMAN, Attorney General
Elinor R. Hoffmann, Assistant Attorney General
Sarah Hubbard, Assistant Attorney General
New York
Office of the Attorney General
Antitrust Bureau
26th Floor, 120 Broadway
New York, NY 10271
212416-8262
elinor.hoffmann(a)a4.ny.4ov
ROY COOPER, Attorney General
K. D. Sturgis, Assistant Attorney General
North Carolina
North Carolina Department of Justice
P.O. Box 629
Raleigh, NC 27602
919-716-6011
ksturpisCaDncdoi.gov
WAYNE STENEHJEM, Attorney General
Elin S. Alm, Assistant Attorney General
Consumer Protection & Antitrust Division
North Dakota
Office of Attorney General of North Dakota
Gateway Professional Center
1050 E. Interstate Ave., Suite 200
Bismarck, ND 58503-5574
701-328-5570
ealm nd.gov
ADDENDUM B:
JPMC Municipal Bond Derivatives Notice Packet
State
Attorney General & Assistant AG
MICHAEL DEWINE, Attorney General
Doreen Johnson, Assistant Section Chief, Antitrust Section
Ohio
Ohio Attorney General's Office
150 E. Gay St, 23rd Floor
Columbus, OH 43215
614-466-4328
doreen.iohnsonCaD-ohioattornev4eneral.Qov
JOHN R. KROGER, Attorney General
Tim D. Nord, Senior Assistant Attorney General
Oregon
Department of Justice
1162 Court Street NE
Salem, OR 97301-4096
503-934-4400
tim.d.nord(&doi.state.or.us
LINDA L. KELLY, Attorney General
James A. Donahue, III
Chief Deputy Attorney General
Pennsylvania
Office of Attorney General
Antitrust Section
14th Floor, Strawberry Square
Harrisburg, PA 17120
717-787-4530
idonahueCa.attorneygeneral.gov
ALAN W ILSON, Attorney General
J.C. Nicholson, III, Assistant Attorney General
Office of South Carolina Attorney General
South Carolina
1000 Assembly Street
Rembert C. Dennis Bldg.
Post Office Box 11549
Columbia, South Carolina 29211
803-734-9916
JCNicholson(cDscaa ctov
ADDENDUM B:
JPMC Municipal Bond Derivatives Notice Packet
State
Attorney General & Assistant AG
MARK L. SHURTLEFF, Attorney General
Ronald J. Ockey, Assistant Attorney General
Utah
Office of the Attorney General of Utah
160 East 300 South, Fifth Floor
Salt Lake City, Utah 84114
801-366-0359
rockey(cDutah. qov
ROBERT E. COOPER, JR. , Attorney General
Victor J. Domen, Jr., Senior Counsel
Tennessee
Tennessee Attorney General's Office
425 Fifth Avenue North
Nashville, TN 37202
615-253-3327
Vic.Domen(cD-ag.tn. qov
GREG ABBOTT, Attorney General
Bret Fulkerson, Assistant Attorney General
Texas
Texas Attorney General's Office
300 West 15th Street, Floor 7
Austin, Texas 78701
512-463-4012
bret.fulkerson UU.oaq.state.tx.us
J.B. VAN HOLLEN, Attorney General
Gwendolyn J. Cooley, Assistant Attorney General
Wisconsin
Wisconsin Department of Justice
17 W. Main St.
Madison, WI 53707-7857
608-261-5810
cooleygi(cD-doi. state.wi. us