EFTA00037109.pdf
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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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