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

process here—is standard operating procedure for class or mass action sexual abuse settlements and notably was approved in the Deutsche Bank case. See Deutsche Bank, 22-cv-02854-JSR, ECF No. 121. 4. Jane Doe 7's Objection to the Proposed Attorneys' Fees Is Meritless. The Court should reject Jane Doe 7's Object

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

had investigated Epstein's relationship with major banks. In early 2021, we decided to make a concerted effort to develop cases against JPMorgan and Deutsche Bank, the two primary banks on which Epstein had relied. 8. We recognized the risks such cases entailed. We recognized that no such case had been previ

com EDWARDS POTTINGER Brittany N. Henderson 1501 Broadway Floor 12 New York, NY (954)-524-2820 Fax: (954)-524-2820 Email: [email protected] David Boies Boies Schiller Flexner LLP 55 Hudson Yards New York, New York Telephone: (212) 446-2300 Facsimile: (212) 446-2350 E-mail: dboiesabsfllp.com Sigr

(954)-524-2820 Email: [email protected] David Boies Boies Schiller Flexner LLP 55 Hudson Yards New

the context of the heightened scrutiny that should have occurred in the monitoring of a high-risk customer." 81. The NYSDFS also found fault with Deutsche Bank's failure to obtain answers regarding Epstein's use of his accounts to pay women with Eastern European surnames: "In a May 2018 email, a compliance o