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Case 1:23-cv-03903-JSR Document 26 Filed 07/06/23 Page 1 of 2

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

Master Case No. 1:23-CV-03903
IN RE JP MORGAN CHASE & CO. (JSR)
DERIVATIVE LITIGATION DERIVATIVE ACTION

DECLARATION OF AUDRA J. SOLOWAY IN SUPPORT
OF DEFENDANTS’ MOTION TO DISMISS
THE AMENDED STOCKHOLDER DERIVATIVE COMPLAINT

AUDRA J. SOLOWAY declares the following pursuant to 28 U.S.C. § 1746:

1. I am a member of the law firm Paul, Weiss, Rifkind, Wharton & Garrison

LLP, 1285 Avenue of the Americas, attorneys for defendants Stephen Burke, Todd Combs, James

Crown, Timothy Flynn, Mellody Hobson, John Kessler, and Phebe Novakovic (together, with

JPMorgan Chase & Co. and James Dimon, “Defendants”). I submit this declaration in support of

Defendants’ Motion to Dismiss the Amended Stockholder Derivative Complaint.

2. Attached hereto as Exhibit 1 is a true and correct copy of the Deferred

Prosecution Agreement and accompanying exhibits, entered into by JPMorgan Chase Bank, N.A.

and the Office of the United States Attorney for the Southern District of New York on January 6,

2014.

3. Attached hereto as Exhibit 2 is a true and correct copy of the Restated

Certificate of Incorporation of JPMorgan Chase & Co., effective April 5, 2006 (incorporated by

reference to Exhibit 3.1 to the Current Report on Form 8-K of JPMorgan Chase & Co. filed April

7, 2006).
Case 1:23-cv-03903-JSR Document 26 Filed 07/06/23 Page 2 of 2

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: July 6, 2023.
New York, New York

/s/ Audra J. Soloway

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