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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
pulation. To the extent there is any conflict between the definitions of capitalized terms in this Notice and the Stipulation, the definition in the Stipulation controls. EFTA00146745 any Jeffrey Epstein sex trafficking venture, between January 1, 1998, and through August 10, 2019. This includes, but is n
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
pulation. To the extent there is any conflict between the definitions of capitalized terms in this Notice and the Stipulation, the definition in the Stipulation controls. A copy of the Stipulation is available by contacting the Claims Administrator or visiting the website [X]. 1 EFTA01652930 Case 1:22-cv
OR SETTLEMENT PURPOSES ONLY SETTLEMENT AGREEMENT AND RELEASE This Settlement Agreement and Release ("Agreement") is entered into by and among (a) Jeffrey Epstein, Financial Trust Company, Inc. ("FTC") and The C.O.U.Q. Foundation, Inc. ("COUQ", and together with Jeffrey Epstein and FTC, the "Claimants"), and (
ement") is entered into by and among (a) Jeffrey Epstein, Financial Trust Company, Inc. ("FTC") and The C.
e ("Agreement") is entered into by and among (a) Jeffrey Epstein, Financial Trust Company, Inc. ("FTC") an
f this Agreement. Bear Steams shall cause its counsel to deliver to each Party's counsel a filed stamped copy of the Stipulation promptly after the Stipulation has been filed. 3. Release by Respondents. In consideration of the release and covenants provided for in paragraphs 2, 4 and 5 of this Agreement,
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
o the extent there is any conflict between the definitions of capitalized terms in these Settlement Forms and the Stipulation, the definition in the Stipulation controls. A copy of the Stipulation is available by contacting the Claims Administrator or by visiting the website (www.epsteinSSFJPM.com), as more
Entities connected to both Jeffrey Epstein and Stipulation

Prince Andrew
PERSON
Bradley Edwards
PERSON
JPMorgan Chase
ORGANIZATIONthe Southern District
LOCATION
David Boies
PERSON
the United States District Court
ORGANIZATIONthe State of New York
LOCATION
Brittany Henderson
PERSON
Henderson
LOCATIONJed S. Rakoff
PERSON
Daniel Patrick Moynihan
PERSONWilmerHale
ORGANIZATIONQuestionnaire
LOCATIONthe "Court
ORGANIZATIONthe Stipulation of Settlement
ORGANIZATIONDeutsche Bank Aktiengesellschaft
ORGANIZATIONthe Term Sheet
ORGANIZATIONthe Released Defendant Parties
ORGANIZATIONthe Settlement Forms
ORGANIZATIONAllocated Amount
ORGANIZATION