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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
LAWYERS BE PAID? BSF and EHL, as Class Counsel, will file a motion for an award of attorneys' fees, costs, and expenses that will be considered at the Settlement Hearing. Class Counsel will apply for an attorneys' fee award in an amount not to exceed thirty percent (30%) of the Global Settlement Amount, plus payment
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
of the dates on which the appropriate federal official and the appropriate state officials are provided with notice pursuant to CAFA, the Court hold the Settlement Hearing and approve the Settlement of the Litigation as set forth herein. At or after the Settlement Hearing, Class Counsel also will request that the Cour
, 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
formation regarding Class Counsel's application for an award of attorneys' fees and expenses. It provides specifics on the date, time, and place of the Settlement Hearing and set forth the procedures for 15 EFTA00145661 Case 1:22-cv-10019-JSR Document 256 Filed 11/02/23 Page 20 of 23 both submitting valid and time
Entities connected to both Jeffrey Epstein and the Settlement Hearing

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