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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
eased Defendant Party shall be deemed to have, and by operation of the Judgment shall have, expressly waived the provisions, rights, and benefits of California Civil Code § 1542, which provides: A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT TO EXIST I
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
eased Defendant Party shall be deemed to have, and by operation of the Judgment shall have, expressly waived the provisions, rights, and benefits of California Civil Code § 1542, which provides: A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in
s, CA 90067 Attorneys for Defendant Jason Child Jeffrey Goldenhersh Skadden, Arps, Slate, Meagher & Flom
to defraud Protempo into providing an up-front payment of $1,910,794 and to pay other sums, such as to constitute fraud, oppression and malice under California Civil Code section 3294. By virtue of Defendant's willful and wrongful conduct, Protempo is entitled to punitive and exemplary damages. SECOND CAUSE OF
Entities connected to both Jeffrey Epstein and California Civil
Leon Black
PERSON
United States
LOCATION
Brittany Henderson
PERSON
Henderson
LOCATIONQuestionnaire
LOCATIONthe Stipulation of Settlement
ORGANIZATIONDeutsche Bank Aktiengesellschaft
ORGANIZATIONStipulation
ORGANIZATIONthe Released Defendant Parties
ORGANIZATIONthe Settlement Forms
ORGANIZATION