Epstein Secrets

seq., on behalf of themselves and the entire nationwide class. On April 17, 2014, Richard Kahn filed a putative class action against defendants in the United States District Court for the For internal use only SDNY_GM_00057234 CONFIDENTIAL-PURSUANTTOFED.R.WhfiI E)EENTFIAL_ DB-SONY-0020058 EFTA_00 I 67802 EFTA01295899 Pa

asserting the eighteen federal and state law claims, including claims for breach of express warranty, breach of implied warranty, and violation of the Magnuson-Moss Warranty Act, 15 U.S.C. Section 2301 et seq., on behalf of themselves and the entire nationwide class. On April 17, 2014, Richard Kahn filed a putative class a

alf of the twelve statewide classes. Id. ¶¶ 120- 337. On April 17, 2014, Plaintiff Richard Kahn filed a putative class action against Defendants in the United States District Court for the Eastern District of New York dealing with similar subject matter. Kahn v. BMW of North America, LLC, 2:14-cv-02463-ADS-ARL. Plaintiff Kahn'

teen causes of action, including claims for breach of express warranty, id. 11198-105, breach of implied warranty, id. ¶¶ 106-119, and violation of the Magnuson-Moss Warranty Act, 15 U.S.C. § 2301 et seq., id. ¶¶ 132-38, on behalf of themselves and the entire nationwide class. Plaintiffs also bring state law claims on behalf

seq., on behalf of themselves and the entire nationwide class. On April 17, 2014, Richard Kahn filed a putative class action against defendants in the United States District Court for the For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0053171 CONFIDENTIAL SDNY_GM_00199355 EFTA01363240

asserting the eighteen federal and state law claims, inc u ing claims for breach of express warranty, breach of implied warranty, and violation of the Magnuson-Moss Warranty Act, 15 U.S.C. Section 2301 et seq., on behalf of themselves and the entire nationwide class. On April 17, 2014, Richard Kahn filed a putative class a