Epstein Secrets

ereinafter referred to collected as "Deutsche Bank"), participating in and financially benefitting from their direct and intentional involvement in Jeffrey Epstein's sex-trafficking venture by providing the financial lifeblood and infrastructure for the venture's continued operation. Deutsche Bank knowingly bene

ank knowingly benefited and received things of value for assisting, supporting, facilitating, and otherwise providing the most critical tool for the Jeffrey Epstein sex-trafficking organization to successfully rape, sexually assault, and coercively sex traffic Plaintiff and the numerous other members of

ngly benefited and received things of value for assisting, supporting, facilitating, and otherwise providing the most critical tool for the Jeffrey Epstein sex-trafficking organization to successfully rape, sexually assault, and coercively sex traffic Plaintiff and the numerous other members of the clas

pliance, Americas, reiterated the ARRC's decision in an email to other executives, stating that ARRC had agreed to "continue business as usual with Jeff Epstein" based upon Packard's "due diligence [bar] visit with him." Deutsche Bank knew, and was acting in reckless disregard of the fact, that Epstein's 65

f Florida found that some of the victims "went to Mr. Epstein's house only once, some went there as much as 10

ficials have repeatedly called the Bank's private banking wealth management business in the Americas as a "key geographic region." Karimi et al. v. Deutsche Bank Aktiengesellschaft et at, Case No. 2:20-cv-08978-ES-JRA (case later transferred to this Court, Case No. 1:22-cv-02854-JSR) ("Karim?), Second Amended Complaint (Dkt. 3

19 (JSR) CLASS ACTION LAWSUIT DECLARATION OF OBJECTOR/CLASS MEMBER declare as follows: I. My name is and I am a victim and survivor of not only Jeffrey Epstein's crimes but the criminal activities of countless others, many of whom have not been brought to justice and many of whom may never be brought to justi

his employer, JP Morgan Chase Bank. 1 EFTA00144588 3. Adam repeatedly advised me not to go to the police or reveal any information I had about Epstein and his illegal activities. He moved into my home in London, and Adam gaslit me into believing this was in my best interest. 4. Adam also thought

me is and I am a victim and survivor of not only Jeffrey Epstein's crimes but the criminal activities of

news for representing women with claims against Mr. Epstein." 19. I am asking the Court to investigate thes

TED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE 1, individually, and on behalf of all others similarly situated, Plaintiff, v. Deutsche Bank Aktiengesellschaft, et. al, Defendants JPMorgan Chase Bank, N.A., Defendants. Case No.: 1:22-CV-10018 (JSR) & Consolidated Case No.: 1:22-CV-10019 (JSR) CLASS ACT

Description of the Litigation and the Class This Notice relates to a proposed settlement of claims in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture, which alleged, among other things, that Defendant violated the Trafficking Victims Protection Act ("TVPA") by p

is Case 5. This case grew out of our firms' long representation of the survivors of Jeffrey Epstein's sex trafficking ring. EHL began representing Epstein survivors in 2009. BSF began representing Epstein survivors in the first half of 2014. 6. By 2021, our firms had successfully brought lawsuits aga

s in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture,

s in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture, w

fficking venture, and the impact of the alleged conduct on the Participating Claimant, and the extent of recovery, if any, in Jane Doe 1, et al, v. Deutsche Bank Aktiengesellschaft, et. al., Case No. 1:22- CV-10018 (JSR). 5.3 Participating Claimants shall submit under penalty of perjury such other supporting documents or mate

, ECF No. 235.1 I. INTRODUCTION This litigation resulted in a historic, globally publicized $290 million settlement agreement for the survivors of Jeffrey Epstein. In its order granting preliminary approval of the Settlement, the Court found the Settlement to be fair, reasonable, and adequate, and authorized N

lan of Allocation, and fee request. HI. THE COURT SHOULD OVERRULE JANE DOE 7'S OBJECTION. On September 15, 2023, an individual purporting to be an Epstein victim and wishing to remain anonymous under the pseudonym Jane Doe 7, filed "Objections to the Proposed Settlement" and an accompanying declaratio

illion settlement agreement for the survivors of Jeffrey Epstein. In its order granting preliminary approv

s sex trafficking venture, and the impact of the alleged conduct on the Participating Claimant, and the extent of recovery in Jane Doe I, et al, v. Deutsche Bank Aktiengesellschaft, et. al., Case No. 1:22-CV- 10018 (JSR)." ECF No. 181-2 at 6. 14 EFTA00145660 Case 1:22-cv-10019-JSR Document 256 Filed 11/02/23 Page 19 of 23 a

ing information: the circumstances, severity, type, and extent of the alleged abuse or trafficking, the nature and duration of the relationship with Jeffrey Epstein, and the impact of the alleged conduct on the Participating Claimant. Participating Claimants shall submit under penalty of perjury such other suppo

tional information you which to share with the Claims Administrator including any additional information about the harm you suffered as a result of Epstein's conduct if not already described in your prior answers. 12. Everything that you submit to the Claims Administrator will be kept completely confide

the nature and duration of the relationship with Jeffrey Epstein, and the impact of the alleged conduct on

e is only intended to release the Released Defendant Parties and is not intended to release any claims against any Person in the case of Jane Doe v. Deutsche Bank Aktiengesellschaft, et al., Case No. 1:22-CV-10018 (JSR), or to preclude class member lawsuits against any other individual or entity not specifically named in the Li

TED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE I, individually, and on behalf of all others similarly situated, Plaintiff, v. Deutsche Bank Aktiengesellschaft, et. al, Defendants JPMorgan Chase Bank, N.A., Defendants. Case No.: 1:22-CV-10018 (JSR) & Consolidated Case No.: 1:22-CV-10019 (JSR) CLASS ACT

23 is whether the settlement, taken as a whole, is fair, adequate, and reasonable"). OBJECTOR'S STATUS AS A CLASS MEMBER Objector is a survivor of Jeffrey Epstein ("Epstein") and qualifies as a Class Member of the preliminarily certified class with standing to object to the proposed Stipulation as provided in

settlement, taken as a whole, is fair, adequate, and reasonable"). OBJECTOR'S STATUS AS A CLASS MEMBER Objector is a survivor of Jeffrey Epstein ("Epstein") and qualifies as a Class Member of the preliminarily certified class with standing to object to the proposed Stipulation as provided in the Stipu

ATUS AS A CLASS MEMBER Objector is a survivor of Jeffrey Epstein ("Epstein") and qualifies as a Class Memb