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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
1, 1998, and through August 10, 2019. This includes, but is not limited to, (1) individuals under the age of 18 who engaged in sexual contact with Epstein and/or a person connected to or otherwise associated with Epstein, and received money or something else of value in exchange for engaging in that s
in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture, w
in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture, wh
t's conduct through its non-typical banking relationship with Epstein damaged victims of Epstein's sex trafficking venture. Defendant denies all of the Class Representative's claims, allegations, and contentions of fault, liability, wrongdoing, and damages. Defendant contends that they had a normal banking relationship wi
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
has spent substantial time communicating with same. 18. BSF and EHL began collaborating on this matter in 2021. BSF took a lead role in drafting the Class Representative's opposition to Defendant's motion to dismiss and arguing it before the Court, resulting in the Court denying Defendant's motion, in part, and allowin
, 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
, which she requested because of the personal and traumatizing experiences described in her complaint. ECF No. 22. Jane Doe 7 does not need to know the Class Representative's name to assess her adequacy to represent the Class, which was explained at length in her prior motions for class certification and in support of app
Entities connected to both Jeffrey Epstein and the Class Representative's

Prince Andrew
PERSON
Bradley Edwards
PERSON
JPMorgan Chase
ORGANIZATIONJane Doe
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
Deutsche Bank
ORGANIZATION
David Boies
PERSONSigrid McCawley
PERSON
the United States District Court
ORGANIZATION
Brittany Henderson
PERSON
Henderson
LOCATION
Boies Schiller Flexner LLP
ORGANIZATIONAction
ORGANIZATIONJed S. Rakoff
PERSON
Daniel Patrick Moynihan
PERSONWilmerHale
ORGANIZATIONthe "Court
ORGANIZATIONQuestionnaire
LOCATIONAndrew Villacastin
PERSON