EFTA01380446

Deutsche Bank Trust Company Americas 345 Park Avenue, 10154-0004 New York. NY. USA Tel. +1 212 454.2369 Fax +1 -44 7 Mobile +1 Email #Positivelmpact From: Stewart Oldfield Sent: Wednesday, November 07, 2018 5:12 PM To: Andrew Gallivan . 3.; Kimberly Hart a Cc: Bradley Gitlin .1 ); Richard larossi Subject: FW: Epstein - negative media [II I have more info as outlined below based on a conversation with Jeffrey's lawyer. Andrew — please confirm that you remain comfortable with the business risk here. Kim — please forward as necessary Summary of situation: This was a frivolous lawsuit that was quickly withdrawn by the plaintiff attorneys upon response from Epstein's lawyers. The person ultimately behind the lawsuit was Steven Hoffenberg, who was convicted of fraud and served a long jail sentence. Hoffenberg was called "unstable" and "manic" by the judge that sentenced him. He repeatedly filed lawsuits against the government from jail and against other people (including his lawyers), all of which were dismissed. He convinced the plaintiffs to file this suit as a class action. That way Hoffenberg wouldn't be the plaintiff himself. The original matter here was thoroughly investigated by the SEC and others and Hoffenberg was the only person deemed to have been involved. If you Google Hoffenberg, it's easy to find the full history here. I think we should accept this matter as closed on our side. Thanks From: Richard larossi Sent: Thursday, October 18 2018 5:22 PM To: Kimberly Hart Cc: Bradley Gillin Stewart Oldfield Subject: RE: Epstein - negative media [I] Classification: For internal use only Hi Kim, AML Compliance (Yoonsun) has requested that we receive your approval to move forward on all Southern Financial/Epstein KYC remediation's. CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0078875 CONFIDENTIAL SDNY_GM_00225059 EFTA01380446