Epstein Project

EFTA00037109.pdf

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pdf
Source set
data-set-8

Original source

Extracted text

Case 1:22-cv-10019-JSR Document 247 Filed 10/19/23 Page 1 of 9 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
JANE DOE I, individually, and on behalf 
of all others similarly situated, 
Plaintiff, 
v. 
Deutsche Bank Aktiengesellschaft, et. al, 
Defendants 
JPMorgan Chase Bank, N.A., 
Defendants. 
Case No.: 1:22-CV-10018 (JSR) & 
Consolidated Case No.: 1:22-CV-10019 (JSR) 
CLASS ACTION LAWSUIT 
OBJECTIONS TO PROPOSED SETTLEMENT 
INCLUDING NOTICE OF INTENT TO APPEAR AT FAIRNESS HEARING 
Class Member 
by and through her attorneys of record, Marsh Law Firm 
PLLC, hereby makes the following objections to the Settlement of this Litigation, in accordance 
with the terms and conditions provided for in the Stipulation of Settlement dated June 22, 2023 
(the "Stipulation"). The objections stated herein apply to the Objector individually as well as to a 
particular subset of the putative class members.' 
Pursuant to Rule 23(e) of the Federal Rules of Civil Procedure ("FRCP"), the Court may 
approve a proposal only upon a finding that it is "fair, reasonable, and adequate." As set forth 
herein, Objector objects to the terms of the Stipulation as failing to satisfy the requirements of 
FRCP Rule 23 and therefore, the proposed Stipulation should be rejected. In tv Michael Milken 
& Assocs. Sec. Litig., 150 F.R.D. 57, 65 (S.D.N.Y. 1993) ("[t]he ultimate test for the exercise of 
Objector hereby incorporates by reference herein the Objections set forth in Jane Doe #7's 
Objections (Dkt. 218). 
1 
EFTA00037109


Case 1:22-cv-10019-JSR Document 247 Filed 10/19/23 Page 2 of 9 
the Court's discretion in approving a settlement of a class action pursuant to Rule 23 is whether 
the settlement, taken as a whole, is fair, adequate, and reasonable"). 
OBJECTOR'S STATUS AS A CLASS MEMBER 
Objector is a survivor of Jeffrey Epstein ("Epstein") and qualifies as a Class Member of 
the preliminarily certified class with standing to object to the proposed Stipulation as provided in …

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