Epstein Secrets

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

ferred, by order of the Judicial Panel on Multidistrict Litigation, to the UntiedUnacd States District Court for the Southern District of New York (the "Court"), entitled Financial Trust Company, Inc. v. The Bear Stearns Companies Inc., No. 10 Civ. 1226 (RWS) (_.) (the "Action"), and, by order of the Cou

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

transferred, by order of the Judicial Panel on Multidistrict Litigation, to the United States District Court for the Southern District of New York (the "Court"), entitled Financial Trust Company, Inc. v. The Bear Stearns Companies Inc., No. 10 Civ. 1226 (RWS) (S.D.N.Y.) (the "Action"), and, by order of th

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

transferred, by order of the Judicial Panel on Multidistrict Litigation, to the United States District Court for the Southern District of New York (the "Court"), entitled Financial Trust Company, Inc. v. The Bear Stearns Companies Inc., No. 10 Civ. 1226 (RWS) (S.D.N.Y.) (the "Action"), and, by order of th

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,

ITIGATION The Litigation is currently pending before Judge Jed S. Rakoff in the United States District Court for the Southern District of New York (the "Court"). The initial complaint in this action was filed on November 24, 2022, and JPMC moved to dismiss the initial complaint on December All capitalized

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

transferred, by order of the Judicial Panel on Multidistrict Litigation, to the United States District Court for the Southern District of New York (the "Court"), entitled Financial Trust Company, Inc. v. The Bear Stearns Companies Inc., No. 10 Civ. 1226 (RWS) (S.D.N.Y.) (the "Action"), and, by order of th