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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
shall determine a Participating Claimant's assigned settlement amount (the "Allocated Amount") from the Global Settlement Amount. In determining an Allocated Amount, the Claims Administrator shall consider the following: a. Questionnaire and Release: As discussed above, Class Members who wish to qualify as Par
, 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
timely Questionnaire and Release, does not opt out of the Class, and is not otherwise deemed ineligible by the Claims Administrator will receive an Allocated Amount. The Plan describes the various factors and criteria the Claims Administrator will take into consideration in determining an Allocated Amount.' The
("GVI") has established a mental health fund (the "Mental Health Fund") to provide a financial resource for mental health services for survivors of Jeffrey Epstein that I will be administering. As a Class Member of both the Epstein DB Fund and the Epstein JPM Fund, you are eligible to apply for approved mental
Simone Lelchuk, Claims Administrator Epstein Survivors' Settlement Fund JPM do Freika PLL Ja
urce for mental health services for survivors of Jeffrey Epstein that I will be administering. As a Class
he guidelines and evaluation factors enumerated in Section 5.2 of the JPM Stipulation and the totality of the circumstances, I have determined your Allocated Amount is One Million Dollars ($1,000,000.00). Massive, LLC has advised that there is no withholding required as a result of medical liens and your distrib
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
articipating Claimant's assigned settlement amount (the "Allocated Amount") from the Net Settlement Fund. In determining a Participating Claimant's Allocated Amount, the Claims Administrator shall consider the following information: the circumstances, severity, type, and extent of the alleged abuse or traffickin
Entities connected to both Jeffrey Epstein and Allocated Amount

Prince Andrew
PERSON
Bradley Edwards
PERSON
JPMorgan Chase
ORGANIZATIONJane Doe
PERSON
David Boies
PERSON
Brittany Henderson
PERSON
Henderson
LOCATION
Boies Schiller Flexner LLP
ORGANIZATIONJed S. Rakoff
PERSONQuestionnaire
LOCATIONAndrew Villacastin
PERSONthe Stipulation of Settlement
ORGANIZATIONDeutsche Bank Aktiengesellschaft
ORGANIZATIONStipulation
ORGANIZATIONthe Class Representative's
ORGANIZATIONthe Settlement Hearing
ORGANIZATIONthe Settlement Forms
ORGANIZATIONLelchuk
LOCATIONthe Released Defendant Parties
ORGANIZATIONSimone K. Lelchuk
PERSON