Epstein Secrets

Don LLP 60 State Street Boston, Massachusetts 02109 Tel: (617) 526-6000 [email protected] [email protected] Counsel for ,IPMorgan Chase Bank, N.A. 37 EFTA01652928 Case 1:22-cv-10019-JSR Document 181-2 Filed 06/22/23 Page 1 of 13 EXHIBIT A-1 EFTA01652929 Case 1:22-cv-10019-JSR Docum

igible Class Members: Defendant; members of the Immediate Family of any Defendant who is an individual; current and former directors and officers of JPMorgan Chase Bank N.A.; Defendant's current and former legal representatives, heirs, successors, or assigns, and any entity in which Defendant has or had a controlling int

n, and (ii) requests such a meeting. f. Trtitgi : The Claims Administrator shall provide in writing to Claimants' Counsel and counsel for JPMorgan Chase Bank, N.A., simultaneously and in a manner that ensures confidentiality, the Allocated Amounts for all Participating Claimants on the same date within a

forth my background as a mediator to provide context for the comments that follow, and to demonstrate that my perspective on the settlement of this Action is rooted in significant experience in the resolution of complex litigation. As described below, this Action presented complicated legal, factual,

le of any BSCI Securities; and/or (I) the ownership at any time of any BSCI Securities. 1.7 "Respondent Releasees" means and includes Respondents, M. Morgan Chase & Co., Deloitte & Touche LLP, and each of their past, current and future predecessors, successors, assigns, limited and general partners, agents, sharehol

the Respondent Releasees, including Representative Claims and any Claims that any Claimant asserted or could have asserted in the Arbitration, the Action; or the Consolidated Action, that in any way arise out of, are connected with or relate to: (a) any of the HG Funds or the ABS Funds (together, the

1/02/23 Page 3 of 23 TABLE OF AUTHORITIES Cases Bellifemine v. Sanoft—Aventis U.S. LLC, 2010 WL 3119374 (S.D.N.Y. Aug. 6, 2010) 2 Davis v..113. Morgan Chase & Co., 827 F. Supp. 2d 172 (W.D.N.Y. 2011) 2 Doe I v. Deutsche Bank Aktiengesellschaft et aL, 22-cv-02854-JSR (S.D.N.Y.) (Rakog J.) 4, 12 Geiss v. We

he Court should ignore these baseless allegations. M— the administrator of the Epstein Victims' Compensation Program, which ended long before this Action was filed and is unrelated to the Settlement—is not a Claims Administrator in this case, and Jane Doe 7 fails to 8 EFTA00145654 Case 1:22-cv-100

ale of any BSCI Securities; and/or (j) the ownership at any time of any BSCI Securities. 1.7 "Respondent Releasees" means and includes Respondents, J.P. Morgan Chase & Co., Deloitte & Touche LLP, and each of their past, current and future predecessors, successors, assigns, limited and general partners, agents, sharehol

ds 2 Settlement Payment. - 5- I KU ,11,11c2 %in= EFTA00615379 2.1 In consideration of the dismissal with prejudice of the Arbitration and the Action and the releases in favor of the Respondent Releasees by Claimants set forth in paragraph 3.1, and in full and final satisfaction of all Claimant Re

ale of any BSCI Securities; and/or (j) the ownership at any time of any BSCI Securities. 1.7 "Respondent Releasees" means and includes Respondents, J.P. Morgan Chase & Co., Deloitte & Touche LLP, and each of their past, current and future predecessors, successors, assigns, limited and general partners, agents, sharehol

ownership interest in any of the Funds. 2. Settlement Payment. 2.1 In consideration of the dismissal with prejudice of the Arbitration and the Action and the releases in favor of the Respondent Releasees by Claimants set forth in - 5 - EFTA00283095 paragraph 3.1, and in full and final satisfact

sale of any BSCI Securities; and/or 0) the ownership at any time of any BSCI Securities. 1.7 "Respondent Releasees" means and includes Respondents, J.P. Morgan Chase & Co., Deloitte & Touche LLP, and each of their past, current and future predecessors, successors, assigns, limited and general partners, agents, sharehol

s, affiliates, parents and subsidiaries. 2. Settlement Payment. 2.1 In consideration of the dismissal with prejudice of the Arbitration and the Action and the releases in favor of the Respondent Releasees by Claimants set forth in paragraph 3.1, and in full satisfaction of all Claims asserted and/o