EFTA Document EFTA01582853

Confidential Due Diligence Report Executive Summary On 1/23/2009, GS&I was requested by Mary Casey to conduct a background investigation. Media research was conducted on 116 East 65Th St., LLC and Robert Maxwell. Throughout this search, the following records were researched: Company and corporate records, RDC (Regulatory Data Corp), MIS (McDonald Information Services), Factiva (Public Figures & Associates Database), CSSS/FPS internal database search (JPMorgan Chase Fraud Prevention List Review), state & federal court searches, personal particulars, publications, regulatory sanctions, F1NRA/NFA and OFAC (Office of Foreign Asset Control). Please Note: All research is subject to the availability of electronic database resources. Our searches revealed the following: Robert Maxwell • Internal database search revealed the following: Reference the account(s) titled "Ghislaine Maxwell" for previous research. The following information was previously reported to Mary Reith on 03/17/2003 under the account Ghislaine Maxwell (DDR # 1185/03): Several newspaper articles detailing the investigation conducted by Britain's Serious Fraud Office against Robert Maxwell. He allegedly used pension funds to service debts, cover operating losses, gamble in the foreign exchange markets, and support the stock of his publicly held companies. The agency is also looking into a complaint from Swiss Bank Corp., which says it did not receive collateral fora $100 million loan to a small private Maxwell company. Newspaper article dated 12/01/2000, which stated that "Ghislaine Maxwell's source of wealth is being classified as something of a mystery." Newspaper article dated 08/09/1996 detailing the arrest of Ghislaine Maxwell on DWI charges. Numerous newspaper articles detailing the criminal fraud charges brought against Kevin and Ian Maxwell (sons of Robert Maxwell). The following information was previously reported to Mary Rauh on 10/20/2005 under the account Forums, LLC (DDR # 11374/04): Newspaper article dated 6/23/2005 detailing Robert Maxwell misappropriated funds from the companies under his control. According to the newspaper article, "He pledged assets as security for additional loans", but instead of delivering the assets to the lender, he would simply sell the assets for cash. "For example, Berlitz language school was supposedly sold to a Japanese Confidential - This report is not to be disseminated or photocopied to any third party wipAGE the express consent of Global Security & Investigations. [ FILENAME ) Confidential Treatment Requested by JPMorgan Chase JPM-SDNY-00062431 EFTA01582853