5
Shared Docs
5
Same-Page
5 / 6
Mentions
process here—is standard operating procedure for class or mass action sexual abuse settlements and notably was approved in the Deutsche Bank case. See Deutsche Bank, 22-cv-02854-JSR, ECF No. 121. 4. Jane Doe 7's Objection to the Proposed Attorneys' Fees Is Meritless. The Court should reject Jane Doe 7's Object
ft et al., 22-cv-02854-JSR (S.D.N.Y.) (Rakoff, J.), ECF No. 121-122. As set forth below, the Court should overrule the Jane Doe 7 Objection because Jane Doe 7 failed to follow the Court-ordered procedure (and thereby waived her ability to make an objection), and because her substantive arguments and factua
EDWARDB HENDERSON LEHRMAN LLC 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 Telephone: (954) 524-2820 Counsel for Class Representative Jane Doe I and the Class EFTA00145643 Case 1:22-cv-10019-JSR Document 256 Filed 11/02/23 Page 2 of 23 TABLE OF CONTENTS I. INTRODUCTION 1 II. THE CLA
the context of the heightened scrutiny that should have occurred in the monitoring of a high-risk customer." 81. The NYSDFS also found fault with Deutsche Bank's failure to obtain answers regarding Epstein's use of his accounts to pay women with Eastern European surnames: "In a May 2018 email, a compliance o
ews reports contained in JP Morgan's due diligence reports-Epstein purchased at the age of 14. Like other women who received payments from Epstein, Jane Doe 1 listed Epstein's apartments on 66th Street in New York City as her address, which should have been a red flag to JP Morgan. 67. Epstein and/or his
the context of the heightened scrutiny that should have occurred in the monitoring of a high-risk customer." 81. The NYSDFS also found fault with Deutsche Bank's failure to obtain answers regarding Epstein's use of his accounts to pay women with Eastern European surnames: "In a May 2018 email, a compliance o
uropean surnames who were publicly and internally identified as Epstein recruiters and/or victims. For example, Epstein paid more than $600,0000 to Jane Doe 1, a woman who—according to news reports contained in JP Morgan's due diligence reports-Epstein purchased at the age of 14. Like other women who recei
oney Market Individual 2 2 0 1 0 NOW & SuperNOW) 4 4 4 3 3 TOTAL 764 71 42 56 36 I DBAGNY is the New York branch of Deutsche Bank AG ("Deutsche Bank" or "the Bank"). DBAGNY Preferred Deposit accounts offer higher interest rates than accounts opened through Deutsche Bank Trust Company Americas ("D
e suit. 5 Gut. thLink & Rockenbach, P.A. Lesley Groff 19 $5,509,464 Jeffrey Epstein Link & Rockenbach represented Groff and Epstein in the Jane Doe 43 lawsuit. It is possible that these payments were made solely for the benefit of Epstein. The transaction dates coincide with the lawsuit. " Se
the context of the heightened scrutiny that should have occurred in the monitoring of a high-risk customer." 81. The NYSDFS also found fault with Deutsche Bank's failure to obtain answers regarding Epstein's use of his accounts to pay women with Eastern European surnames: "In a May 2018 email, a compliance o
of 18 U.S.C. §§ 1591(a)(1) & (a)(2) by aiding, abetting, and inducing Epstein's and his conspirators sex-trafficking venture and sex trafficking of Jane Doe 1, as well as other Class Members. As a consequence, Jane Doe 1, as well as other members of the Class, are victims of JP Morgan's criminally aiding,
Entities connected to both Deutsche Bank and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
United States
LOCATION
Julie K. Brown
PERSON
Scarlett Johansson
PERSONDarren Indyke
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONMaria Farmer
PERSONthe Southern District
LOCATIONLeon Black
PERSONSouthern District
LOCATION
Alexander Acosta
PERSON
Paul Morris
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATIONJack Scarola
PERSON