Epstein Secrets

the Settlement and Plan of Allocation, and award the requested attorneys' fees and expenses. Dated: November 2, 2023 Respectfully submitted, /s/ David Boies David Boies Andrew Villacastin Sabina Mariella Alexander Law Boies Schiller Flexner LLP 55 Hudson Yards New York, NY Telephone: (212) 446-2300

ember 2, 2023 Respectfully submitted, /s/ David Boies David Boies Andrew Villacastin Sabina Mariella

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

behalf of all others similarly situated, Plaintiff, v. JPMorgan Chase Bank, N.A., Defendant. Case No. 1:22-CV-10019 (JSR) JOINT DECLARATION OF DAVID BOIES AND BRADLEY EDWARDS IN SUPPORT OF CLASS REPRESENTATIVE JANE DOE 1'S MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT WITH DEFENDANT JPMO

. 1:22-CV-10019 (JSR) JOINT DECLARATION OF DAVID BOIES AND BRADLEY EDWARDS IN SUPPORT OF CLASS REPRESEN

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,

Searcy Denney Scarola Barnhart & Shipley PA, or Boies Schiller Flexner LLP, on the one hand and any and

Date Pledged Indebtedness or Assigned 10. For each account receivable, or note receivable you had immediately prior to the commencement of this Action, at the beginning of each calendar year thereafter during the period in question and as of the present date, set forth the name, address and teleph

, Searcy Denney Scarola Barnhart & Shipley PA, or Boies Schiller Flexner LLP, and/or any and all attorne

rogatories contractors or individuals (including, wi ' • services provided to or for the benefit of you, Jane Doe andk in connection with this Action, or any other matters pertaining to or involving Jeffrey Epstein. Include in your response the format in which any such promises, contracts, agreem

BSF Si rid McCawle Tele hone: Email: BOIES SCHILLER FLEXNER August 7, 2017 VIA EMAIL Mi

in your letter to Judge Koeltl as follows: "We respectfully submit that the Plaintiff's Evidence provides grounds for this Court to dispose of the Action entirely, inter alia, under Rule 12(b)(2) for lack of personal jurisdiction. Because the Defendants have no present connection to New York upon whi

BSF Si 'cl McCawle Tele hone: Email: BOIES SCHILLER FLEXNER August 7, 2017 VIA EMAIL Mi

in your letter to Judge Koeltl as follows: "We respectfully submit that the Plaintiff's Evidence provides grounds for this Court to dispose of the Action entirely, inter alia, under Rule 12(b)(2) for lack of personal jurisdiction. Because the Defendants have no present connection to New York upon whi

, Searcy Denney Scarola Barnhart & Shipley PA, or Boies Schiller Flexner LLP, and/or any and all attorne

(including, without limitation, witnesses) for services provided to or for the benefit of you, LM, EW, Jane Doe and/or M) in connection with this Action, or any other matters pertaining to or involving Jeffrey Epstein. Include in your response the format in which any such promises, contracts, agreem

oena for documents sought for a federal action.” c. Category 3 — Documents that Contain Personal Financial Information Completely Irrelevant to this Action Defendant also wrongfully abuses the subpoena power to seek personal financial information from this non-party. See Woodward v. Berkery, 714 So. 2d

lso containing discussion of Ms. Giuffre’s affidavit). The Court should be aware that within approximately two hours of this exchange, Ms. McCawley. (David Boies’ law partner) released a statement on his behalf, which stated that Dershowitz was misrepresenting what happened: “Because the discussions that Mr. Bo

s’ law partner) released a statement on his behalf, which stated that Dershowitz was misrepresenting what happened: “Because the discussions that Mr. Boies had with Mr. Dershowitz were expressly privileged settlement discussions, Mr. Boies will not, at least at this time, describe what was actually sai

en AUSA appeared before Judge McMahon barely four months later, however, he told her none of this, unequivocally and falsely disavowing any role by Boies Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his office before November 2018. Even though AUSA had

y prosecution after a second meeting with attorneys, which took place after at least one of Maxwell's depositions. As reported in the Daily News, "David [Boles] was particularly frustrated by the failure to pursue a perjury charge.s13 "We have her dead to rights," he said.14 This Court cannot accept without

or Boies Schiller had anything to do with the Government's decision to convene a grand jury to look into the matters that were the subject of the Action. On the contrary—the Government has advised the Court that it contacted Boies Schiller as part of its search for parties who might have been victim

Judge McMahon that the prosecutors had no idea what was in Boies Schiller's file. Indeed, he insisted, there had been no contact whatsoever between Boies Schiller and United States Attorney's Office before the government commenced its investigation. Nor, said the prosecutor, did Boies Schiller have a

, AUSA met with attorneys from Boies Schiller, who "urged to open an investigation of Epstein and Maxwell!' Then, after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking "if the Southern District would consider charging Maxwell with perjury."

or Boies Schiller had anything to do with the Government's decision to convene a grand jury to look into the matters that were the subject of the Action. On the contrary—the Government has advised the Court that it contacted Boies Schiller as part of its search for parties who might have been victim