Epstein Secrets

are entering into this Agreement solely to avoid the inconvenience and unnecessary expenditure of time and resources associated with litigating the Action and any other matters among the Parties. All communications (whether oral, in writing or in electronic form), agreements, documents, or other mater

d thereby but rather shall be enforced to the greatest extent permitted by law. 19. Governing Law This Agreement shall be governed by the laws of the State of New York applicable to agreements made, and to be performed, therein, without resort to the conflict of law provisions or rules of New York or any other jur

the Respondent Releasees, including Representative Claims and any Claims that any Claimant asserted or could have asserted in the Arbitration, the Action; or the Consolidated Action, that in any way arise out of, are connected with or relate to: (a) any of the HG Funds or the ABS Funds (together, the

ning Law. This Agreement and any claims or disputes arising hereunder shall be governed by and interpreted in accordance with the internal laws of the State of New York, without regard to principles of conflict of laws, except to the extent that federal law requires that federal law govern. 16.11 Evidentiary Rules.

are entering into this Agreement solely to avoid the inconvenience and unnecessary expenditure of time and resources associated with litigating the Action and any other matters among the Parties. All communications (whether oral, in writing or in electronic form), agreements, documents, or other mate

er shall be enforced to the greatest extent permitted by law. 5 EFTA00731223 19. Governing Law This Agreement shall be governed by the laws of the State of New York applicable to agreements made, and to be performed, therein, without resort to the conflict of law provisions or rules of New York or any other jur

ds 2 Settlement Payment. - 5- I KU ,11,11c2 %in= EFTA00615379 2.1 In consideration of the dismissal with prejudice of the Arbitration and the Action and the releases in favor of the Respondent Releasees by Claimants set forth in paragraph 3.1, and in full and final satisfaction of all Claimant Re

ning Law. This Agreement and any claims or disputes arising hereunder shall be governed by and interpreted in accordance with the internal laws of the State of New York, without regard to principles of conflict of laws, except to the extent that federal law requires that federal law govern. 16.11 Evidentiary Rules.

by Thomas J. McGowan, Esq. whose hourly rate is $440.00 and Pedram Tabibi, Esq. whose hourly rate is $225.00. In order to proceed as counsel in the Action, the Firm will require a retainer of $7,500. The retainer shall be applied to any services that have already been and will be rendered on behalf of

ELEPHONE: FACSIMILE: INTERNET: Video Conference Facilities Part 1215 to Title 22 of the Official Compilations of Codes, Rules and Regulations of the State of New York, entitled "Written Letter of Engagement" require that law firms and their clients enter into written Engagement Agreements in most situations. This

by Thomas J. McGowan, Esq. whose hourly rate is $440.00 and Pedram Tabibi, Esq. whose hourly rate is $225.00. In order to proceed as counsel in the Action, the Firm will require a retainer of $7,500. The retainer shall be applied to any services that have already been and will be rendered on behalf of

TELEPHONE: FACSIMILE: INTERNET Video Conference Facilities Pan 1215 to Title 22 of the Official Compilations of Codes, Rules and Regulations of the State of New York, entitled "Written Letter of Engagement" require that law firms and their clients enter into written Engagement Agreements in most situations. This

ownership interest in any of the Funds. 2. Settlement Payment. 2.1 In consideration of the dismissal with prejudice of the Arbitration and the Action and the releases in favor of the Respondent Releasees by Claimants set forth in - 5 - EFTA00283095 paragraph 3.1, and in full and final satisfact

ning Law. This Agreement and any claims or disputes arising hereunder shall be governed by and interpreted in accordance with the internal laws of the State of New York, without regard to principles of conflict of laws, except to the extent that federal law requires that federal law govern. 16.11 Evidentiary Rules.

forth my background as a mediator to provide context for the comments that follow, and to demonstrate that my perspective on the settlement of this Action is rooted in significant experience in the resolution of complex litigation. As described below, this Action presented complicated legal, factual,

NT JPMORGAN CHASE BANK N.A. We, David Boies and Bradley Edwards, declare as follows: I. I, David Boies, am a member in good standing of the bar of the State of New York and am admitted to practice before this Court. I am the Chairman and a Managing Partner of Boies Schiller Flexner LLP ("BSF"). I make this declarat

by Thomas J. McGowan, Esq. whose hourly rate is $440.00 and Pedram Tabibi, Esq. whose hourly rate is $225.00. In order to proceed as counsel in the Action, the Firm will require a retainer of $7,500. The retainer shall be applied to any services that have already been and will be rendered on behalf of

York, New York 10065 INTERNET: Video Conference Facilities Part 1215 to Title 22 of the Official Compilations of Codes, Rules and Regulations of the State of New York, entitled "Written Letter of Engagement" require that law firms and their clients enter into written Engagement Agreements in most situations. This

s, affiliates, parents and subsidiaries. 2. Settlement Payment. 2.1 In consideration of the dismissal with prejudice of the Arbitration and the Action and the releases in favor of the Respondent Releasees by Claimants set forth in paragraph 3.1, and in full satisfaction of all Claims asserted and/o

ning Law. This Agreement and any claims or disputes arising hereunder shall be governed by and interpreted in accordance with the internal laws of the State of New York, without regard to principles of conflict of laws, except to the extent that federal law requires that federal law govern. - 14 - KU 23311357i EF