JPMorgan Epstein Settlement Agreement
EXHIBIT 1 Case 1:22-cv-10019-JSR Document 181-1 Filed 06/22/23 Page 1 of 38 1 135762625_7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Case No. 1:22-CV-10019 (JSR) STIPULATION OF SETTLEMENT This Stipulation of Settlement, dated June 22, 2023 (the “Stipulation”), is made and entered into by and between: (i) Class Representative Jane Doe 1 (“Jane Doe 1” or “Class Representative”), on behalf of herself and each Class Member, by and through her counsel of record in the Litigation;1 and (ii) Defendant JPMorgan Chase Bank, N.A. (“JPMC” or the “Bank”) by and through its counsel of record in the Litigation. The Stipulation is intended to fully, finally, and forever resolve, discharge, and settle the Released Claims, subject to the approval of the Court and the terms and conditions set forth herein. I. THE LITIGATION The Litigation is currently pending before Judge Jed S. Rakoff in the United States District Court for the Southern District of New York (the “Court”). The initial complaint in this action was filed on November 24, 2022, and JPMC moved to dismiss the initial complaint on December 1 All capitalized terms not otherwise defined shall have the meanings ascribed to them in § IV.1 herein. Jane Doe 1, individually and on behalf of all others similarly situated, Plaintiff, v. JPMorgan Chase Bank, N.A., Defendant. Case 1:22-cv-10019-JSR Document 181-1 Filed 06/22/23 Page 2 of 38 2 135762625_7 30, 2022. Class Representative filed an Amended Complaint (the “Complaint”) on January 13, 2023, which alleged that Defendant violated the Trafficking Victims Protection Act (“TVPA”), 18 U.S.C. §§ 1591, 1594, 1595. The Complaint further alleged Defendant aided, abetted, and facilitated battery, committed intentional infliction of emotional distress, negligently failed to exercise reasonable care to prevent physical
Summary
EXHIBIT 1 Case 1:22-cv-10019-JSR Document 181-1 Filed 06/22/23 Page 1 of 38 1 135762625_7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Case No. 1:22-CV-10019 (JSR) STIPULATION OF SETTLEMENT This Stipulation of Settlement, dated June 22, 2023 (the “Stipulation”), is made and entered into by and between: (i) Class Representative Jane Doe 1 (“Jane Doe 1” or “Class Representative”), on behalf of herself and each Class Member, by and through her counsel of record in the Litigation;1 and (ii) Defendant JPMorgan Chase Bank, N.A. (“JPMC” or the “Bank”) by and through its counsel of record in the Litigation. The Stipulation is intended to fully, finally, and forever resolve, discharge, and settle the Released Claims, subject to the approval of the Court and the terms and conditions set forth herein. I. THE LITIGATION The Litigation is currently pending before Judge Jed S. Rakoff in the United States District Court for the Southern District of New York (the “Court”). The initial complaint in this action was filed on November 24, 2022, and JPMC moved to dismiss the initial complaint on December 1 All capitalized terms not otherwise defined shall have the meanings ascribed to them in § IV.1 herein. Jane Doe 1, individually and on behalf of all others similarly situated, Plaintiff, v. JPMorgan Chase Bank, N.A., Defendant. Case 1:22-cv-10019-JSR Document 181-1 Filed 06/22/23 Page 2 of 38 2 135762625_7 30, 2022. Class Representative filed an Amended Complaint (the “Complaint”) on January 13, 2023, which alleged that Defendant violated the Trafficking Victims Protection Act (“TVPA”), 18 U.S.C. §§ 1591, 1594, 1595. The Complaint further alleged Defendant aided, abetted, and facilitated battery, committed intentional infliction of emotional distress, negligently failed to exercise reasonable care to prevent physical
Forum Discussions
This document was digitized, indexed, and cross-referenced with 1,500+ persons in the Epstein files. 100% free, ad-free, and independent.