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

ust submit a Questionnaire and Release to the Claims Administrator." ECF No. 181-2, at 2. Jane Doe 7 does not claim to have ever submitted either a Questionnaire and Release or an opt-out form to the Class Administrator before filing her Objection. Jane Doe 7 also fails to establish that she is a Class Membe

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Jane Doe 1, individually and on behalf of all others similarly situated, Plaintiff, v. JPMorgan Chase Bank, N.A., Defendant. Case No.: 1:22-CV-10019 (JS R

O CONTACT CLASS COUNSEL IN ORDER TO PARTICIPATE IN DISTRIBUTION OF THE SETTLEMENT FUND? No. If you have received this Notice and timely submit your Questionnaire and Release to the designated address, you need not contact Class Counsel. If your address changes, please contact the Claims Administrator at: Si

AND RELEASE TO BE you (or counsel on your behalf) must submit a Questionnaire and ELIGIBLE TO RECEIVE A Release to the Claims Administrator. The Questionnaire and PAYMENT Release must be postmarked (if mailed) or received (if submitted online) on or before September 5, 2023 at 11:59PM EDT. If the Claims

Simone Lelchuk, Claims Administrator Epstein Survivors' Settlement Fund JPM do Freika PLL January 16, 2024 VIA EMAIL ( II) do Marsh Law Firm Re: Jane Doe 1 v. JP Morgan Chase Bank, N.A., Case No. 22-cv-10019 (JSR) Dear Ms. Thank you for trusting me to evaluate your claims as part of the Epstein Survivo

ted to me from Participating Claimants and this letter ("Determination Notice") constitutes notice of your Allocated Amount. After considering your Questionnaire and Release using the guidelines and evaluation factors enumerated in Section 5.2 of the JPM Stipulation and the totality of the circumstances, I ha

sanctions pursuant to Rule 30(dX2) aril (3)(A) and (C) (referencing Rule 37(aX5)), Federal Rules of Civil Procedure and compelling the deposition of Jane Doe No. 4 within fifteen (15) days and as grounds therefore would state: 1. On August 16, 2009, the deposition of Jane Doe No. 4 was noticed for Septe

.; Stuart Memcbtein; Ashlie Stoker-Badng; Connie Zagulrre Subject Jane Does v. Epstein From reviewing the transcripts, it seems Dr. Kliman utilized Questionnaire's with all of your clients. I need them. Please advise of your position. I'm sure you will produce since they are EXHIBIT 3 9/15/2009 09/12/2019

has met her burden, should the Court consider adopting such extraordinary relief. On its face, the motion does not meet the necessary burden as to Jane Doe 4, or Jane Does 2, 3, 5, 6, or 7. Discussion of Law Requiring the Denial of the Requested Protective Order Rule 26(c)(1XE), Fed.R.Civ P. (2009), gove

Stuart Mermeistein; Ashlie Stoken-Baring; Connie Zaguirre Subject Jane Does v. Epstein From reviewing the transcripts, it seems Dr. Kliman utilized Questionnaire's with all of your clients. I need them. Please advise of your position. I'm sure you will produce since they are EXHIBIT 3 If 9/15/2009 EFTA001

has met her burden, should the Court consider adopting such extraordinary relief. On its face, the motion does not meet the necessary burden as to Jane Doe 4, or Jane Does 2, 3, 5, 6, or 7. Discussion of Law Requiring the Denial of the Requested Protective Order Rule 26(c)(1XE), Fed.R.Civ P. (2009), gove

Stuart Mermeisteln; Ashlie Stoken-Baring; Connie Zaguirre Subject Jane Does v. Epstein From reviewing the transcripts, it seems Dr. Kliman utilized Questionnaire's with all of your clients. I need them. Please advise of your position. I'm sure you will produce since they are EXHIBIT 3 If 9/15/2009 EFTA016