Epstein Secrets

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

on—the method by which the Settlement Fund is distributed to the Class- "must be fair and adequate." Facebook, 343 F. Supp. 3d at 414 (quoting In re WorldCom, Inc. Sec. Litig., 388 F. Supp. 2d 319, 344 (S.D.N.Y. 2005)); see Fed. R. Civ. P. 23(e)(2). Where, as in this case, a Plan of Allocation is "formul

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

ns and legislation have been put into place; and many other business firms--established ones like General Electric and Xerox, newer ones like Tyco, WorldCom, and Global Crossing--have undergone probes or have even dissolved. Mean-while, the tacit or demonstrable complicity of members of boards of directo

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doc to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

ons and legislation have been put into place; and many other business firms—established ones like General Electric and Xerox, newer ones like Tyco, WorldCom, and Global Crossing—have undergone probes or have even dissolved. Mean-while, the tacit or demonstrable complicity of members of boards of director

there, in facts far different from those presented here, the defendant admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

ns and legislation have been put into place; and many other business firms--established ones like General Electric and Xerox, newer ones like Tyco, WorldCom, and Global Crossing--have undergone probes or have even dissolved. Mean-while, the tacit or demonstrable complicity of members of boards of directo