Doe 1 v. Deutsche Bank Aktiengesellschaft et al
| Jane Doe 1 |
| Deutsche Bank Aktiengesellschaft, Deutsche Bank AG New York Branch and Deutsche Bank Trust Company Americas |
| Government of the United States Virgin Islands |
| JP Morgan Chase & Co. and JPMorgan Chase Bank, N.A. |
| Epstein Victims Compensation Program and Jordana H. Feldman |
| 1:2022cv10018 |
| November 24, 2022 |
| US District Court for the Southern District of New York |
| Jed S Rakoff |
| Other Statutory Actions |
| 28 U.S.C. § 1331 ra Fed. Question: Racketeering (RICO) Act |
| Plaintiff |
Docket Report
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Filing 95
AMENDED ORDER GRANTING PRELIMINARY APPROVAL PURSUANT TO FED. R. CIV. P. 23(e)(l) AND PERMITTING NOTICE TO THE CLASS re: #91 Order on Motion for Settlement. IT IS HEREBY ORDERED: 1. The Court has reviewed the Stipulation and does hereby preliminarily approve the Stipulation and the Settlement set forth therein as fair, reasonable, and adequate, subject to further consideration at the Settlement Hearing (as defined in paragraph 3 below). 2. The Court preliminarily finds that the proposed Settlement should be approved as it: (i) is the result of good faith, extensive arm's-length and non-collusive negotiations; (ii) falls within a range of reasonableness warranting final approval; (iii) has no obvious deficiencies; and (iv) warrants notice of the proposed Settlement to Class Members and further consideration of the Settlement at the Settlement Hearing described below. 3. A hearing shall be held before this Court on October 20, 2023, at 4:00p.m. (the "Settlement Hearing"), at the Daniel Patrick Moynihan United States Courthouse, United States District Court for the Southern District of New York, 500 Pearl Street, New York, NY 10007, to: (a) determine whether the proposed Settlement of the Litigation on the terms and conditions provided for in the Stipulation is fair, reasonable, and adequate to the Class and should be approved by the Court; (b) determine whether a Judgment as provided in paragraph 1.15 of the Stipulation should be entered; ( c) determine whether the proposed Plan of Allocation as described in the Stipulation and Notice (as defined below) should be approved; (d) determine the amount of attorneys' fees, costs, charges, and expenses that should be awarded to Class Counsel; ( e) hear any objections by Class Members to the Settlement or Plan of Allocation, the award of attorneys' fees and expenses to Class Counsel; and (f) consider such other matters the Court deems appropriate. The Court may adjourn or change the date and time of the Settlement Hearing without further notice to the Class. The Court approves the form, substance, and requirements of the Notice of Proposed Settlement of Class Action ("Notice"), substantially in the form annexed hereto as Exhibit A-1. 5. The Court approves the form of the Summary Notice of Proposed Settlement of Class Action ("Summary Notice"), substantially in the form annexed hereto as Exhibit A-2. 6. Simone Lelchuk (the "Claims Administrator") is hereby appointed to supervise and administer the notice procedure as well as the processing of Claims as more fully set forth below. 7. No later than June 28, 2023, 2023 (the "Notice Date"), the Claims Administrator shall cause a copy of the Notice, Tier One Form, and Tier Two Questionnaire and Release to be mailed by First-Class Mail to all Class Members who can be identified with reasonable effort and to be posted on the case-designated website. For all Notices returned as undeliverable, the Claims Administrator shall use her best efforts to locate updated addresses. 8. No later than July 11, 2023, the Claims Administrator shall cause the Summary Notice to be published once in USA Today and Gazeta Wyborcza. 9. At least forty-five (45) calendar days prior to the Settlement Hearing, or September 5, 2023, Class Counsel shall serve on Defendants' Counsel and file with the Court proof, by affidavit or declaration, of such mailing and publishing. All fees, costs, and expenses incurred in identifying and notifying Class Members shall be shared equally by the Class and Defendants, with the Class's portion to be reimbursed from the Global Settlement Amount. 12. All Class Members shall be bound by all determinations and judgments in the Litigation concerning the Settlement (including, but not limited to, the releases provided for therein) whether favorable or unfavorable to the Class, regardless of whether such Persons seek or obtain by any means (including, without limitation, by submitting a Tier One Form and/or Tier Two Questionnaire and Release, or any similar document) any distribution from the Settlement Fund or the Net Settlement Fund. 13. In order to receive funds from the Settlement, Class Members ( or Class Counsel, on their behalf) must submit a Tier One Form. Unless the Court orders otherwise, all Tier One Forms must be postmarked or submitted electronically no later than forty-five (45) calendar days from the Notice Date, or August 12, 2023. If deemed eligible by the Claims Administrator, such Claimants ("Eligible Class Members") will receive $75,000. Eligible Class Members who wish to receive an additional Allocated Amount up to $5,000,000 (inclusive of the $75,000 available to all Eligible Class Members) from the Net Settlement Fund shall complete and submit a Tier Two Questionnaire and Release in accordance with the instructions contained therein. Unless the Court orders otherwise, all Tier Two Questionnaires and Releases must be postmarked or submitted electronically no later than sixty (60) calendar days from the Notice Date, or August 27, 2023. Any Class Member who does not submit a Tier Two Questionnaire and Release within the time provided shall be barred from sharing in any additional distribution of the proceeds of the Net Settlement Fund, unless otherwise ordered by the Court, but shall in all other respects be bound by the terms of the Stipulation and by any final judgment entered by the Court. (as further set forth herein). IT IS SO ORDERED. (Settlement Conference set for 10/20/2023 at 04:00 PM before Judge Jed S. Rakoff.) (Signed by Judge Jed S. Rakoff on 6/27/2023) (kv) Transmission to Finance Unit (Cashiers) for processing.
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Filing 94
NOTICE of Class Representative's Notice of Filing of Stipulation of Settlement. Document filed by Jane Doe 1. (Attachments: #1 Exhibit 1 - Amended Stipulation of Settlement).(Edwards, Bradley)
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Minute Entry for proceedings held before Judge Jed S. Rakoff: Telephone Conference held on 6/26/2023 without transcription or recording. Counsel for all parties were present. The parties are instructed to submit a proposed amended order incorporating the two-day extension to the Notice Date and with the other relevant deadlines adjusted by close of business tomorrow, June 27, 2023, for the Courts signature. (Kotowski, Linda)
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Filing 93
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 6/1/2023 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR, 1:22-cv-10904-JSR.(McGuirk, Kelly)
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Filing 92
TRANSCRIPT of Proceedings re: CONFERNECE held on 6/1/2023 before Judge Jed S. Rakoff. Court Reporter/Transcriber: Sharonda Jones, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 7/11/2023. Redacted Transcript Deadline set for 7/21/2023. Release of Transcript Restriction set for 9/18/2023.Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR, 1:22-cv-10904-JSR.(McGuirk, Kelly)
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Filing 91
ORDER GRANTING PRELIMINARY APPROVAL PURSUANT TO FED. R. CIV. P. 23(e)(l) AND PERMITTING NOTICE TO THE CLASS granting #81 Motion for Settlement; granting #84 Motion for Settlement; granting #88 Motion for Settlement. IT IS HEREBY ORDERED: 1. The Court has reviewed the Stipulation and does hereby preliminarily approve the Stipulation and the Settlement set forth therein as fair, reasonable, and adequate, subject to further consideration at the Settlement Hearing (as defined in paragraph 3 below). 2. The Court preliminarily finds that the proposed Settlement should be approved as it: (i) is the result of good faith, extensive arm's-length and non-collusive negotiations; (ii) falls within a range of reasonableness warranting final approval; (iii) has no obvious deficiencies; and (iv) warrants notice of the proposed Settlement to Class Members and further consideration of the Settlement at the Settlement Hearing described below. A hearing shall be held before this Court on October 20, 2023, at 4:00 p.m. (the "Settlement Hearing"), at the Daniel Patrick Moynihan United States Courthouse, United States District Court for the Southern District of New York, 500 Pearl Street, New York, NY 10007, to: (a) determine whether the proposed Settlement of the Litigation on the terms and conditions provided for in the Stipulation is fair, reasonable, and adequate to the Class and should be approved by the Court; (b) determine whether a Judgment as provided in paragraph 1.15 of the Stipulation should be entered; ( c) determine whether the proposed Plan of Allocation as described in the Stipulation and Notice (as defined below) should be approved; (d) determine the amount of attorneys' fees, costs, charges, and expenses that should be awarded to Class Counsel; (e) hear any objections by Class Members to the Settlement or Plan of Allocation, the award of attorneys' fees and expenses to Class Counsel; and (f) consider such other matters the Court deems appropriate. The Court may adjourn or change the date and time of the Settlement Hearing without further notice to the Class. The Court approves the form, substance, and requirements of the Notice of Proposed Settlement of Class Action ("Notice"), substantially in the form annexed hereto as Exhibit A-1. The Court approves the form of the Summary Notice of Proposed Settlement of Class Action ("Summary Notice"), substantially in the form annexed hereto as Exhibit A-2. Simone Lelchuk the "Claims Administrator") is hereby appointed to supervise and administer the notice procedure as well as the processing of Claims as more fully set forth below. No later than ten (10) calendar days after entry of this Order, or July 11, 2023, the Claims Administrator shall cause the Summary Notice to be published once in USA Today and Gazeta Wyborcza. At least forty-five (45) calendar days prior to the Settlement Hearing, or September 5, 2023, Class Counsel shall serve on Defendants' Counsel and file with the Court proof, by affidavit or declaration, of such mailing and publishing. In order to receive funds from the Settlement, Class Members ( or Class Counsel, on their behalf) must submit a Tier One Form. Unless the Court orders otherwise, all Tier One Forms must be postmarked or submitted electronically no later than forty-five (45) calendar days from the Notice Date, or July 31, 2023. If deemed eligible by the Claims Administrator, such Claimants ("Eligible Class Members") will receive $75,000. Eligible Class Members who wish to receive an additional Allocated Amount up to $5,000,000 (inclusive of the $75,000 available to all Eligible Class Members) from the Net Settlement Fund shall complete and submit a Tier Two Questionnaire and Release in accordance with the instructions contained therein. Unless the Court orders otherwise, all Tier Two Questionnaires and Releases must be postmarked or submitted electronically no later than sixty ( 60) calendar days from the Notice Date, or August 15, 2023. (as further set forth herein). IT IS SO ORDERED.. (Signed by Judge Jed S. Rakoff on 6/16/2023) (kv) Transmission to Finance Unit (Cashiers) for processing.
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Filing 90
DECLARATION of David Boies and Bradley Edwards in Support re: #88 MOTION for Settlement Class Representative's Notice of Unopposed Motion for (I) Preliminary Approval of Class Action Settlement; and (II) Approval of Notice to the Class.. Document filed by Jane Doe 1. (Attachments: #1 Exhibit 1 - Amended Stipulation of Settlement, #2 Exhibit A1 to Exhibit 1, #3 Exhibit A2 to Exhibit 1, #4 Exhibit 2 - Declaration of Lelchuk).(Edwards, Bradley)
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Filing 89
MEMORANDUM OF LAW in Support re: #88 MOTION for Settlement Class Representative's Notice of Unopposed Motion for (I) Preliminary Approval of Class Action Settlement; and (II) Approval of Notice to the Class. . Document filed by Jane Doe 1. (Attachments: #1 Exhibit A - Proposed Order Preliminary Approval, #2 Exhibit B - Proposed Order and Final Judgment).(Edwards, Bradley)
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Filing 88
MOTION for Settlement Class Representative's Notice of Unopposed Motion for (I) Preliminary Approval of Class Action Settlement; and (II) Approval of Notice to the Class. Document filed by Jane Doe 1..(Edwards, Bradley)
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Minute Entry for proceedings held before Judge Jed S. Rakoff:. Fairness Hearing set for 10/20/2023 at 04:00 PM before Judge Jed S. Rakoff in courtroom 14B of the Daniel Patrick Moynihan Courthouse, 500 Pearl Street, New York City, New York.. (Kotowski, Linda)
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Filing 87
MOTION Letter Regarding Jointly-Proposed Candidates for Claims Administrator re: #86 Declaration in Support of Motion, Amended Stipulation of Settlement. Document filed by Jane Doe 1. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C).(Edwards, Bradley)
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Filing 86
DECLARATION of David Boies and Bradley Edwards in Support re: #84 MOTION for Settlement Class Representative's Notice of Unopposed Motion for (I) Preliminary Approval of Class Action Settlement; and (II) Approval of Notice to the Class.. Document filed by Jane Doe 1. (Attachments: #1 Exhibit 1 - Amended Stipulation of Settlement, #2 Exhibit A1 to Exhibit 1, #3 Exhibit A2 to Exhibit 1, #4 Exhibit 2 - Declaration of Lelchuk).(Edwards, Bradley)
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Filing 85
MEMORANDUM OF LAW in Support re: #84 MOTION for Settlement Class Representative's Notice of Unopposed Motion for (I) Preliminary Approval of Class Action Settlement; and (II) Approval of Notice to the Class. . Document filed by Jane Doe 1. (Attachments: #1 Exhibit A - Proposed Order Preliminary Approval, #2 Exhibit B - Proposed Order and Final Judgment).(Edwards, Bradley)
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Filing 84
MOTION for Settlement Class Representative's Notice of Unopposed Motion for (I) Preliminary Approval of Class Action Settlement; and (II) Approval of Notice to the Class. Document filed by Jane Doe 1..(Edwards, Bradley)
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Filing 83
DECLARATION of David Boies and Bradley Edwards in Support re: #81 MOTION for Settlement Class Representative's Notice of Unopposed Motion for (I) Preliminary Approval of Class Action Settlement; and (II) Approval of Notice to the Class.. Document filed by Jane Doe 1. (Attachments: #1 Exhibit 1 - Stipulation of Settlement, #2 Exhibit A1 to Exhibit 1, #3 Exhibit A2 to Exhibit 1, #4 Exhibit 2 - Declaration of Lelchuk).(Edwards, Bradley)
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Filing 82
MEMORANDUM OF LAW in Support re: #81 MOTION for Settlement Class Representative's Notice of Unopposed Motion for (I) Preliminary Approval of Class Action Settlement; and (II) Approval of Notice to the Class. . Document filed by Jane Doe 1. (Attachments: #1 Exhibit A - Proposed Order Preliminary Approval, #2 Exhibit B - Proposed Order Final Judgment).(Edwards, Bradley)
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Filing 81
MOTION for Settlement Class Representative's Notice of Unopposed Motion for (I) Preliminary Approval of Class Action Settlement; and (II) Approval of Notice to the Class. Document filed by Jane Doe 1..(Edwards, Bradley)
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Filing 80
ORDER FOR ADMISSION PRO HAC VICE granting #67 Motion to Appear Pro Hac Vice. The motion of Daniel Crispino for admission to practice Pro Hac Vice in the above captioned action is granted. As further set forth by this Order. (Signed by Judge Jed S. Rakoff on 5/25/2023) (tg)
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Minute Entry for proceedings held before Judge Jed S. Rakoff:. Hearing on Class Certification set for 5/26/2023 at 02:00 PM before Judge Jed S. Rakoff in courtroom 14B of 500 Pearl Street, New York City, NY. (Kotowski, Linda)
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Filing 79
NOTICE OF CHANGE OF ADDRESS by Brittany Henderson on behalf of Jane Doe 1. New Address: Edwards Henderson Lehrman PLLC, 425 North Andrews Avenue, Suite 2, Fort Lauderdale, FL, USA 33301, 954-524-2820..(Henderson, Brittany)
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Filing 78
NOTICE OF CHANGE OF ADDRESS by Bradley J Edwards on behalf of Jane Doe 1. New Address: Edwards Henderson Lehrman PLLC, 425 North Andrews Avenue, Suite 2, Fort Lauderdale, FL, USA 33301, 954-524-2820..(Edwards, Bradley)
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Minute Entry for proceedings held before Judge Jed S. Rakoff: Telephone Conference held on 5/17/2023,without transcription or recording. Plaintiffs motion for preliminary approval of proposed class settlement is due by 5/26/2023. A preliminary fairness hearing will be held at 4:00 PM on 6/1/2023 in Courtroom 14B, the Daniel Patrick Moynihan U.S. Courthouse, 500 Pearl St., New York, NY. ( Fairness Hearing set for 6/1/2023 at 04:00 PM before Judge Jed S. Rakoff.). (Kotowski, Linda)
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Minute Entry for proceedings held before Judge Jed S. Rakoff: Erratum: The Courts Minutes of a Telephone Conference held on 5/10/2023 is hereby corrected. Defendants Deutsche Bank and JP Morgan may file separate briefs in support of the joint motion to exclude Ms. Khodarkovsky.. (Kotowski, Linda) Modified on 5/15/2023 (Kotowski, Linda).
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Minute Entry for proceedings held before Judge Jed S. Rakoff: Telephone Conference held on 5/10/2023 without transcription or recording. Counsel for Jane Doe, Deutsche Bank, and JP Morgan were present. Deutsche Bank and JP Morgan may file a joint motion to exclude the testimony of Jane Khodarkovsky by no later than 5:00 PM on 5/12/2023. Plaintiffs may file joint opposition papers by no later than 5:00 PM on 5/22/2023. Reply papers are due by no later than 5:00 PM on 5/25/2023. The Court may hold an evidentiary hearing on this motion before oral argument on plaintiffs motions for class certification on 5/26/2023.. (Kotowski, Linda)
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Filing 77
ORDER FOR ADMISSION PRO HAC VICE in case 1:22-cv-10018-JSR; granting (100) Motion for Paul G. Cassell to Appear Pro Hac Vice in case 1:22-cv-10019-JSR.. (Signed by Judge Jed S. Rakoff on 5/2/2023) Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR, 1:22-cv-10904-JSR (kv)
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Filing 76
NOTICE OF APPEARANCE by Alexander Law on behalf of Jane Doe 1..(Law, Alexander)
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Filing 75
OPINION AND ORDER: For the foregoing reasons, the Court hereby reconfirms its rulings in its "bottom-line" order of March 20, 2023. Defendants' motions to dismiss are therefore granted in part and denied in part, as specified below: With respect to Jane Doe v. Deutsche Bank Aktiengesellschaft et al., 22-cv-10018, the Court grants defendants' motion to dismiss with respect to Counts II, III, IV, V, VII, VIII, IX, and X of the First Amended Complaint. The Court denies defendants motion with respect to Counts I, VI, XI, and XII of the First Amended Complaint. Thus, for clarity, the following claims asserted by plaintiff Jane Doe against defendants Deutsche Bank Aktiengesellschaft, Deutsche Bank AG New York Branch, and Deutsche Bank Trust Company Americas remain as part of the case: (1) the claim that defendants knowingly benefited from participating in a sex-trafficking venture, in violation of 18 U.S.C. 1591(a)(2); (2) the claim that defendants obstructed enforcement of the Trafficking Victims Protection Act, in violation of 18 U.S.C. 1591(d); (3) the claim that defendants negligently failed to exercise reasonable care to prevent physical harm; and (4) the claim that defendants negligently failed to exercise reasonable care as a banking institution providing non-routine banking. All other claims are dismissed. With respect to Jane Doe v. JP Morgan Chase Bank, N.A., 22- cv-10019, the Court grants defendant's motion to dismiss with respect to Counts I, II, VI, VII, VIII, and IX of the First Amended Complaint. The Court denies defendant's motion with respect to Counts III, IV, V, and X of the First Amended Complaint. Thus, for clarity, the following claims asserted by plaintiff Jane Doe against defendant J.P. Morgan Chase Bank, N.A. remain as part of the case: (1) the claim that defendant negligently failed to exercise reasonable care to prevent physical harm; (2) the claim that defendant negligently failed to exercise reasonable care as a banking institution providing non-routine banking; (3) the claim that defendant knowingly benefited from participating in a sex-trafficking venture, in violation of 18 U.S.C. 1591(a)(2); and (4) the claim that defendant obstructed enforcement of the Trafficking Victims Protection Act, in violation of 18 U.S.C. 1591(d). All other claims are dismissed. With respect to Government of the United States Virgin Islands v. JP Morgan Chase Bank, N.A., 22-cv-10904, the Court grants defendant's motion to dismiss with respect to Counts II, III, and IV of the First Amended Complaint. The Court denies defendant's motion with respect to Count I of the First Amended Complaint. Thus, for clarity, the claim of plaintiff the Government of the United States Virgin Islands that defendant JP Morgan Chase Bank, N.A. knowingly benefited from participating in a sex-trafficking venture, in violation of 18 U.S.C. 1591 (a) (2), remains as part of the case. All other claims are dismissed. SO ORDERED. (Signed by Judge Jed S. Rakoff on 5/1/2023) Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR, 1:22-cv-10904-JSR (kv)
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Filing 74
ORDER FOR ADMISSION PRO HAC VICE: The motion of Paul G. Cassell to appear Pro Hac Vice in the above-captioned action is granted. IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules Governing discipline of attorneys. (Signed by Judge Jed S. Rakoff on 5/1/2023) Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR, 1:22-cv-10904-JSR (kv)
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Filing 73
***SELECTED PARTIES***NOTICE of filing of Exhibit AH to David Boies Declaration re: #70 Declaration in Support of Motion,,. Document filed by Jane Doe 1, Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas. Motion or Order to File Under Seal: #41 .(Boies, David)
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Filing 72
***SELECTED PARTIES*** MEMORANDUM OF LAW in Support re: #68 MOTION to Certify Class . . Document filed by Jane Doe 1, Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas. Motion or Order to File Under Seal: #41 .(Boies, David)
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Filing 71
MEMORANDUM OF LAW in Support re: #68 MOTION to Certify Class . . Document filed by Jane Doe 1..(Boies, David)
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Filing 70
***SELECTED PARTIES***DECLARATION of David Boies in Support re: #68 MOTION to Certify Class .. Document filed by Jane Doe 1, Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas. (Attachments: #1 Exhibit C, #2 Exhibit X, #3 Exhibit Y, #4 Exhibit Z, #5 Exhibit AA, #6 Exhibit AB, #7 Exhibit AC, #8 Exhibit AD, #9 Exhibit AE, #10 Exhibit AF, #11 Exhibit AG, #12 Exhibit AI, #13 Exhibit AJ, #14 Exhibit AK, #15 Exhibit AL)Motion or Order to File Under Seal: #41 .(Boies, David)
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Filing 69
DECLARATION of David Boies in Support re: #68 MOTION to Certify Class .. Document filed by Jane Doe 1. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C (Slipsheet), #4 Exhibit D Part 1, #5 Exhibit D Part 2, #6 Exhibit D Part 3, #7 Exhibit E, #8 Exhibit F, #9 Exhibit G, #10 Exhibit H, #11 Exhibit I, #12 Exhibit J, #13 Exhibit K, #14 Exhibit L, #15 Exhibit M, #16 Exhibit N Part 1, #17 Exhibit N Part 2, #18 Exhibit O, #19 Exhibit P, #20 Exhibit Q, #21 Exhibit R, #22 Exhibit S, #23 Exhibit T, #24 Exhibit U, #25 Exhibit V, #26 Exhibit W, #27 Exhibit X (Slipsheet), #28 Exhibit Y (Slipsheet), #29 Exhibit Z (Slipsheet), #30 Exhibit AA (Slipsheet), #31 Exhibit AB (Slipsheet), #32 Exhibit AC (Slipsheet), #33 Exhibit AD (Slipsheet), #34 Exhibit AE (Slipsheet), #35 Exhibit AF (Slipsheet), #36 Exhibit AG(Slipsheet), #37 Exhibit AH (Slipsheet), #38 Exhibit AI (Slipsheet), #39 Exhibit AJ (Slipsheet), #40 Exhibit AK (Slipsheet), #41 Exhibit AL (Slipsheet), #42 Exhibit AM, #43 Exhibit AN, #44 Exhibit AO, #45 Exhibit AP, #46 Exhibit AQ, #47 Exhibit AR, #48 Exhibit AS).(Boies, David)
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Filing 68
MOTION to Certify Class . Document filed by Jane Doe 1..(Boies, David)
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Filing 67
MOTION for Daniel Crispino to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27658256. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Jane Doe 1. (Attachments: #1 Affidavit Declaration of Daniel Crispino, #2 Exhibit Florida Certificate of Good Standing, #3 Text of Proposed Order Proposed Order).(Crispino, Daniel)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #67 MOTION for Daniel Crispino to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27658256. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz)
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Filing 66
ORDER GRANTING MOTION TO APPEAR PRO HAC VICE granting #65 Motion for Kathryn Caldwell to Appear Pro Hac Vice. SO ORDERED.. (Signed by Judge Jed S. Rakoff on 4/24/2023) (kv)
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Filing 65
MOTION for Kathryn Caldwell to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27637776. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas..(Caldwell, Kathryn)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #65 MOTION for Kathryn Caldwell to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27637776. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (sgz)
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Filing 64
ORDER in case 1:22-cv-10018-JSR; granting (85) Motion for Discovery; granting (86) Motion re: (85 in 1:22-cv-10019-JSR) MOTION for Discovery re Jane Doe's Identity., (86 in 1:22-cv-10019-JSR) MOTION (letter) re. Disclosure Under Protective Order Of Class Representative In Parallel Suit . in case 1:22-cv-10019-JSR. Plaintiffs in two of the above-captioned cases are anonymous. For clarity, the Court will refer to plaintiff in Jane Doe v. Deutsche Bank Aktiengesellschaft et al., 22-cv-10018, as "DB Jane Doe." On April 14, 2023, defendant JP Morgan Chase Bank, N.A. ("JP Morgan") and third-party defendant James ("Jes") Staley moved to compel disclosure of DB Jane Doe's identity to them. While DB Jane Doe has a significant privacy interest that weighs against such disclosure, movants have provided the Court with strong reason to believe that she has information that is relevant to their defenses. See Fed. R. Civ. Pro. 2 6 (b) (1) (setting forth the scope of discovery). Thus, the Court hereby grants their motion. Counsel for DB Jane Doe is hereby ordered to disclose DB Jane Doe's identity to JP Morgan and to Jes Staley on a confidential basis, pursuant to the operative protective order in Jane Doe v. JP Morgan Chase Bank, N.A., 22-cv-10019. See ECF No. 35 (the protective order). The Clerk is respectfully directed to close entries numbered 85 and 86 on the docket of this case. SO ORDERED.. (Signed by Judge Jed S. Rakoff on 4/19/2023) Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR, 1:22-cv-10904-JSR (kv)
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Minute Entry for proceedings held before Judge Jed S. Rakoff: Telephone Conference held on 4/13/2023, without transcription or recording. Counsel for all parties were present. With respect to plaintiffs application regarding defendants response to requests for production 1 and 2, the application is denied with respect to the request for Deutsche Bank to review documents previously marked by prior counsel as non-responsive in response to prior regulatory inquiries. However, Deutsche Bank is directed to produce to plaintiff either the document requests and its responses in those actions or other information sufficient to allow plaintiff to determine what the basis was for marking documents as responsive or non-responsive in those proceedings. With respect to plaintiffs requests for production concerning production in the Karimi case, Deutsche Bank is directed to produce all documents produced in that case, as well as the underlying requests for production and its responses. Jane Does request for further production concerning Deutsche Banks anti-money laundering policies and any exceptions from those policies made for particular clients is denied without prejudice to her renewing a more targeted request after she has reviewed the Karimi production if she believes there is further relevant material that should be produced. With respect to the three confidential witnesses from the Karimi case whom Deutsche Bank has not yet designated as custodians, Deutsche Bank should conduct a document review as to the one confidential witness named in Jane Does complaint and should produce relevant documents from that review. Jane Does application is denied as to the two remaining confidential witnesses, although the denial is without prejudice to Jane Does renewing the request following review of the documents produced in the Karimi case if Jane Doe can make a showing that these witnesses may have further relevant documents beyond the scope of what has already been produced. With respect to Deutsche Banks applications for production, counsel for Jane Doe is directed to produce all relevant documents currently in Jane Does counsels production no more than one week from today (as agreed by the parties during the telephonic conference). Further, Deutsche Banks application for further production is granted in so far as Jane Doe shall not withhold as non-responsive any of Jane Does communications to, from, or concerning Jeffrey Epstein, or any of Jane Does communications to, from, or concerning the individual with whom Jane Doe alleges she was in a sham marriage. Deutsche Banks application is denied with respect to communications to, from, or concerning other entities or persons potentially affiliated with Epstein, although this denial is without prejudice to Deutsche Bank renewing the application in a more targeted way. Finally, as concerns Deutsche Banks subpoena to the Jane Doe in 22-cv-10019, Doe v. JP Morgan, Jane Doe in that case shall produce documents or deposition excerpts sufficient to show she is not a class member in this case, as discussed during the telephonic conference. In addition, Jane Doe in that case shall produce any documents in no more than one week from today concerning her communications or interactions with Jane Doe in 22-cv-10018, Doe v. Deutsche Bank, as also discussed and agreed to during the telephonic conference. Deutsche Bank is not required to bear the costs of that production. (Kotowski, Linda)
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Filing 63
ANSWER to #42 Amended Complaint,. Document filed by Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas..(Hennes, David)
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Filing 62
REVISED CIVIL CASE MANAGEMENT PLAN (JUDGE RAKOFF): This Court has set this case for trial on 9-5-2023. After consultation with counsel for the parties, the following Amended Case Management Plan is adopted. This plan is also a scheduling order pursuant to Rules 16 and 26(f) of the Federal Rules of Civil Procedure. The case is to be tried to a jury. Defendants shall file their Answer to plaintiff's First Amended Complaint by April 10, 2023. Motions due by 6/28/2023. Responses due by 7/14/2023 Replies due by 7/21/2023. Deposition due by 6/21/2023. All Fact Discovery due by 5/30/2023. All Expert Discovery due by 6/21/2023. Oral Argument set for 5/26/2023 at 02:00 PM in Courtroom 14B, 500 Pearl Street, New York, NY 10007 before Judge Jed S. Rakoff. Final Pretrial Conference set for 7/28/2023 at 02:00 PM before Judge Jed S. Rakoff. Jury Trial set for 9/5/2023 at 09:30 AM before Judge Jed S. Rakoff. And as set forth herein. SO ORDERED. (Signed by Judge Jed S. Rakoff on 3/28/2023) (ama)
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Set/Reset Deadlines: Deutsche Bank AG New York Branch answer due 4/10/2023; Deutsche Bank Aktiengesellschaft answer due 4/10/2023; Deutsche Bank Trust Company Americas answer due 4/10/2023; JP Morgan Chase & Co. answer due 4/10/2023; JPMorgan Chase Bank, N.A. answer due 4/10/2023. (ama)
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Filing 61
NOTICE OF APPEARANCE by Andrew H. Schapiro on behalf of Epstein Victims Compensation Program, Jordana H. Feldman..(Schapiro, Andrew)
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Filing 60
MEMO ENDORSEMENT on re: (50 in 1:22-cv-10018-JSR) Reply Memorandum of Law in Support of Motion, filed by Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas, Deutsche Bank AG New York Branch. ENDORSEMENT: SO ORDERED. (Signed by Judge Jed S. Rakoff on 3/24/2023) Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR (ate)
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Filing 59
ORDER: For reasons stated from the bench on March 16, 2023, the Court hereby grants JP Morgan's motion in part and denies that motion in part, as further specified below. The Court hereby grants JP Morgan's motion with respect to its Requests for Production numbered 1, 9, 12, 13, 14, and 15. Additionally, the Court hereby grants in part JP Morgan's motion with respect to its Requests for Production numbered 7 and 8. More specifically, the EVCP is hereby ordered to produce documents sufficient to show the total number of applicants to the EVCP who were approved for compensation and the total number of such applicants who were denied such compensation. The EVCP is not hereby compelled to produce documents sufficient to show the reasons for its approval or denial of any application. Additionally, JP Morgan's motion to compel is denied with respect to Requests for Production numbered 13, 16, 17, 18, and 19, which the Court views as overly broad. All documents produced pursuant to this Order are to be produced on an attorneys-eyes-only basis, and are to be made available to counsel for JP Morgan as well as to counsel for defendants in Jane Doe v. Deutsche Bank Aktiengesellschaft et al., 22-cv-10018. All personally identifying information must be redacted from them, and they must be returned (with no records of them kept) once the Court has ruled on class certification in the above-captioned cases. The Clerk is respectfully directed to close entry number 55 on the docket of Jane Doe v. JP Morgan Chase Bank, N.A., 22-cv-10019 and entry number 63 on the docket of Government of the United States Virgin Islands v. JP Morgan Chase Bank, N.A., 22-cv-10904. (Signed by Judge Jed S. Rakoff on 3/24/2023) (ate)
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Filing 58
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a ORAL ARGUMENT proceeding held on 3/13/2023 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR, 1:22-cv-10904-JSR.(McGuirk, Kelly)
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Filing 57
TRANSCRIPT of Proceedings re: ORAL ARGUMENT held on 3/13/2023 before Judge Jed S. Rakoff. Court Reporter/Transcriber: Sonya Ketter Moore, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 4/10/2023. Redacted Transcript Deadline set for 4/20/2023. Release of Transcript Restriction set for 6/20/2023.Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR, 1:22-cv-10904-JSR.(McGuirk, Kelly)
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Filing 56
ORDER granting in part and denying in part (37) Motion to Dismiss; granting in part and denying in part (43) Motion to Dismiss in case 1:22-cv-10018-JSR; granting in part and denying in part (31) Motion to Dismiss; granting in part and denying in part (44) Motion to Dismiss in case 1:22-cv-10019-JSR; granting in part and denying in part (38) Motion to Dismiss in case 1:22-cv-10904-JSR. On February 1, 2023, and February 7, 2023, defendants filed motions to dismiss the operative complaints in the above-captioned cases. Upon consideration of all parties' written submissions and oral argument, the Court hereby grants those motions in part and denies those motions in part, as specified below. An opinion explaining the reasons for these rulings will follow in due course. The Clerk is respectfully directed to close entry numbers 37 and 43 on the docket of 22-cv-10018; numbers 31 and 44 on the docket of 22-cv-10019; and number 38 on the docket of 22-cv-10904. SO ORDERED.. (Signed by Judge Jed S. Rakoff on 3/20/2023) Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR, 1:22-cv-10904-JSR (kv)
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Filing 55
NOTICE OF APPEARANCE by Andrew Buckley Cashmore on behalf of Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas..(Cashmore, Andrew)
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Filing 54
NOTICE OF APPEARANCE by Sabina Mariella on behalf of Jane Doe 1..(Mariella, Sabina)
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Minute Entry for proceedings held before Judge Jed S. Rakoff: Oral Argument held on 3/13/2023 re: #37 MOTION to Dismiss the Individual and Class Action Complaint. filed by Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas, Deutsche Bank AG New York Branch. (Kotowski, Linda)
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Filing 53
ORDER FOR ADMISSION PRO HAC VICE granting #19 Motion for Paul G. Cassell to Appear Pro Hac Vice. IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules Governing discipline of attorneys.. (Signed by Judge Jed S. Rakoff on 3/6/2023) (kv)
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Filing 52
ORDER FOR ADMISSION PRO HAC VICE granting #16 Motion for Sigrid S. McCawley to Appear Pro Hac Vice. IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys.. (Signed by Judge Jed S. Rakoff on 3/6/2023) (kv)
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Filing 51
***SELECTED PARTIES*** REPLY MEMORANDUM OF LAW in Support re: #43 MOTION to Dismiss the First Amended Individual and Class Action Complaint. . Document filed by Deutsche Bank Trust Company Americas, Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Jane Doe 1, Government of the United States Virgin Islands, JP Morgan Chase & Co., JPMorgan Chase Bank, N.A.. Motion or Order to File Under Seal: #41 .(Hennes, David)
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Filing 50
REPLY MEMORANDUM OF LAW in Support re: #43 MOTION to Dismiss the First Amended Individual and Class Action Complaint. . Document filed by Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas..(Hennes, David)
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Filing 49
***SELECTED PARTIES*** MEMORANDUM OF LAW in Opposition re: #43 MOTION to Dismiss the First Amended Individual and Class Action Complaint. . Document filed by Jane Doe 1, Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas, Government of the United States Virgin Islands, JP Morgan Chase & Co., JPMorgan Chase Bank, N.A.. Motion or Order to File Under Seal: #41 .(Boies, David)
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Filing 48
MEMORANDUM OF LAW in Opposition re: #43 MOTION to Dismiss the First Amended Individual and Class Action Complaint. . Document filed by Jane Doe 1..(Boies, David)
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Filing 47
***SELECTED PARTIES***DECLARATION of David B. Hennes in Support re: #43 MOTION to Dismiss the First Amended Individual and Class Action Complaint.. Document filed by Deutsche Bank Trust Company Americas, Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Jane Doe 1, Government of the United States Virgin Islands, JP Morgan Chase & Co., JPMorgan Chase Bank, N.A.. (Attachments: #1 Exhibit A - General Release and Settlement Agreement, #2 Exhibit B - Non-Prosecution Agreement, #3 Exhibit C - Consent Order)Motion or Order to File Under Seal: #41 .(Hennes, David)
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Filing 46
***SELECTED PARTIES*** MEMORANDUM OF LAW in Support re: #43 MOTION to Dismiss the First Amended Individual and Class Action Complaint. . Document filed by Deutsche Bank Trust Company Americas, Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Jane Doe 1, Government of the United States Virgin Islands, JP Morgan Chase & Co., JPMorgan Chase Bank, N.A.. Motion or Order to File Under Seal: #41 .(Hennes, David)
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Filing 45
DECLARATION of David B. Hennes in Support re: #43 MOTION to Dismiss the First Amended Individual and Class Action Complaint.. Document filed by Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas. (Attachments: #1 Exhibit A - General Release and Settlement Agreement, #2 Exhibit B - Non-Prosecution Agreement, #3 Exhibit C - Consent Order).(Hennes, David)
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Filing 44
MEMORANDUM OF LAW in Support re: #43 MOTION to Dismiss the First Amended Individual and Class Action Complaint. . Document filed by Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas..(Hennes, David)
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Filing 43
MOTION to Dismiss the First Amended Individual and Class Action Complaint. Document filed by Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas. Responses due by 2/21/2023.(Hennes, David)
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Filing 42
FIRST AMENDED COMPLAINT amending #1 Complaint against Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas with JURY DEMAND.Document filed by Jane Doe 1. Related document: #1 Complaint..(Edwards, Bradley)
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Filing 41
PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material... SO ORDERED. (Signed by Judge Jed S. Rakoff on 1/12/2023) Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR (kv)
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Minute Entry for proceedings held before Judge Jed S. Rakoff: Telephone Conference held on 1/11/2023, without transcription or recording held on 1/11/2023. Counsel for plaintiff and defendants was present. Any amended complaint will become the operative complaint. Any motions to dismiss the amended complaint must be submitted by no later than 2/7/2023. Responsive papers must be submitted by no later than 2/21/2023, with reply by no later than 2/28/2023. Oral argument will be held at 4:00 PM on 3/13/2023. ( Oral Argument set for 3/13/2023 at 04:00 PM before Judge Jed S. Rakoff.). (Kotowski, Linda)
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Filing 40
NOTICE OF APPEARANCE by Andrew Villacastin on behalf of Jane Doe 1..(Villacastin, Andrew)
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Filing 39
DECLARATION of David B. Hennes in Support re: #37 MOTION to Dismiss the Individual and Class Action Complaint.. Document filed by Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas. (Attachments: #1 Exhibit A - Consent Order under New York Banking Law 39 and 44).(Hennes, David)
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Filing 38
MEMORANDUM OF LAW in Support re: #37 MOTION to Dismiss the Individual and Class Action Complaint. . Document filed by Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas..(Hennes, David)
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Filing 37
MOTION to Dismiss the Individual and Class Action Complaint. Document filed by Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas. Responses due by 1/13/2023.(Hennes, David)
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Filing 36
ORDER: Barring any objection from plaintiff Government of the United States Virgin Islands, which must be made by joint telephone call to Chambers no later than 5:00 PM on January 4, 2023, this case is hereby consolidated for all pretrial purposes with Doe v. Deutsche Bank, 22- cv-10018 and Doe v. JP Morgan Chase & Co., 22-cv-10019. Further, except for any motion to dismiss, this case will be governed by the case management plan dated December 5, 2022, previously entered in those cases. See Doe v. Deutsche Bank, 22-cv-10018, Dkt. 23; Doe v. JP Morgan Chase & Co., 22-cv-10019, Dkt. 16. Counsel for the Government of the United States Virgin Islands and counsel for JP Morgan Chase Bank, N.A. should jointly call Chambers, again by no later than 5:00 PM on January 4, 2023, to set a schedule for any motion to dismiss in this case. SO ORDERED. (Signed by Judge Jed S. Rakoff on 12/29/2022) Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR, 1:22-cv-10904-JSR (kv)
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Filing 35
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 12/5/2022 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR.(McGuirk, Kelly)
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Filing 34
TRANSCRIPT of Proceedings re: CONFERENCE held on 12/5/2022 before Judge Jed S. Rakoff. Court Reporter/Transcriber: George Malinowski, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 1/6/2023. Redacted Transcript Deadline set for 1/17/2023. Release of Transcript Restriction set for 3/16/2023.Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR.(McGuirk, Kelly)
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Filing 33
ORDER re: (4 in 1:22-cv-10019-JSR) MOTION For Leave to Proceed Anonymously re: (1) Complaint . filed by Jane Doe 1, (4 in 1:22-cv-10018-JSR) MOTION For Leave to Proceed Anonymously re: (1) Complaint . filed by Jane Doe 1. Accordingly, on those conditions, plaintiff's motions are hereby granted for all pretrial purposes. SO ORDERED. (Signed by Judge Jed S. Rakoff on 12/5/2022) Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR (kv)
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Filing 32
ORDER granting #15 Motion for James Dowden to Appear Pro Hac Vice. (Signed by Judge Jed S. Rakoff on 12/6/2022) (ate)
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Filing 31
ELECTRONIC SUMMONS ISSUED as to Deutsche Bank Trust Company Americas. (vf)
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Filing 30
ELECTRONIC SUMMONS ISSUED as to Deutsche Bank AG New York Branch. (vf)
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Filing 29
ELECTRONIC SUMMONS ISSUED as to Deutsche Bank Aktiengesellschaft. (vf)
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Minute Entry for proceedings held before Judge Jed S. Rakoff: Initial Pretrial Conference held on 12/6/2022, Defendant's Motion to Dismiss due 12/30/2022, Response due 1/13/2023, replies due 1/20/2023( Hearing in Class certification 5/12/2023 at 4:00pm, Jury Trial set for 8/7/2023 at 09:30 AM before Judge Jed S. Rakoff. This matter is consolidated with 22civ10019 for all pretrial purposes.) (Kotowski, Linda)
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Filing 28
ORDER granting #4 Motion for Leave to Proceed Anonymously re: #4 MOTION For Leave to Proceed Anonymously re: #1 Complaint . Plaintiff in both of the above-captioned cases has moved to proceed anonymously. Defendants have informed the Court that they do not oppose such motions, provided that plaintiff will reveal her identity to the defendants for discovery purposes (on the condition that defendants do not disclose her name to the general public). Accordingly, on those conditions, plaintiff's motions are hereby granted for all pretrial purposes. SO ORDERED. (Signed by Judge Jed S. Rakoff on 12/5/22) (yv)
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Filing 27
ORDER. On the consent of all parties, see transcript 12/5/2022, the above-captioned cases are hereby consolidated for all pre-trial purposes. The Clerk of the Court is respectfully directed to consolidate the cases under the docket number 22-cv-10018-UA but bearing both captions. However, barring further order of the Court, trial of the cases will proceed separately, with 22-cv-10018-UA starting trial on August 7, 2023 and 22-cv-10019-UA starting trial on September 5, 2023. SO ORDERED. (Signed by Judge Jed S. Rakoff on 12/5/22) Filed In Associated Cases: 1:22-cv-10018-JSR, 1:22-cv-10019-JSR (yv)
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Filing 26
REQUEST FOR ISSUANCE OF SUMMONS as to Deutsche Bank Trust Company Americas, re: #1 Complaint. Document filed by Jane Doe 1..(Edwards, Bradley)
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Filing 25
REQUEST FOR ISSUANCE OF SUMMONS as to Deutsche Bank AG New York Branch, re: #1 Complaint. Document filed by Jane Doe 1..(Edwards, Bradley)
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Filing 24
REQUEST FOR ISSUANCE OF SUMMONS as to Deutsche Bank Aktiengesellschaft, re: #1 Complaint. Document filed by Jane Doe 1..(Edwards, Bradley)
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Filing 23
CIVIL CASE MANAGEMENT PLAN: The case is to be tried to a jury. Amended Pleadings due by 1/23/2023. Joinder of Parties due by 12/16/2022. Motion to dismiss - Moving papers 12/30. Answering Papers 1/13. Reply papers - 1/20. Motions in support of class certification due by 3/31/2023. Responses due by 4/21/2023 Replies due by 5/5/2023. Deposition due by 4/24/2023. Discovery due by 4/24/2023. Final Pretrial Conference set for 6/12/2023 at 04:00 PM before Judge Jed S. Rakoff. SO ORDERED. (Signed by Judge Jed S. Rakoff on 12/5/22) (yv)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #19 MOTION for Paul G. Cassell to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27035834. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (aea)
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Filing 22
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent Deutsche Bank AG for Deutsche Bank Trust Company Americas. Document filed by Deutsche Bank Trust Company Americas..(Hennes, David)
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Filing 21
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Corporate Parent Deutsche Bank AG for Deutsche Bank AG New York Branch. Document filed by Deutsche Bank AG New York Branch..(Hennes, David)
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Filing 20
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Deutsche Bank Aktiengesellschaft..(Hennes, David)
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Filing 19
MOTION for Paul G. Cassell to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27035834. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Jane Doe 1. (Attachments: #1 Affidavit Declaration, #2 Exhibit Certificate of Good Standing, #3 Text of Proposed Order Proposed Order).(Cassell, Paul)
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Filing 18
NOTICE OF APPEARANCE by David Boies, II on behalf of Jane Doe 1..(Boies, David)
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Filing 17
PROPOSED CASE MANAGEMENT PLAN. Document filed by Jane Doe 1..(Edwards, Bradley)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #16 MOTION for Sigrid S. McCawley to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27030664. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (aea)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #15 MOTION for James Dowden to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27030464. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (aea)
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Filing 16
MOTION for Sigrid S. McCawley to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27030664. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Jane Doe 1. (Attachments: #1 Affidavit Declaration of Sigrid S. McCawley, #2 Exhibit Florida Certificate of Good Standing, #3 Exhibit District of Columbia Certificate of Good Standing, #4 Text of Proposed Order Proposed Order).(McCawley, Sigrid)
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Filing 15
MOTION for James Dowden to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-27030464. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas..(Dowden, James)
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Filing 14
NOTICE OF APPEARANCE by Michael Ardeljan on behalf of Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas..(Ardeljan, Michael)
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Filing 13
NOTICE OF APPEARANCE by Brittany Henderson on behalf of Jane Doe 1..(Henderson, Brittany)
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Filing 12
NOTICE OF APPEARANCE by Andrew Simon Todres on behalf of Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas..(Todres, Andrew)
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Filing 11
NOTICE OF APPEARANCE by Lisa H. Bebchick on behalf of Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas..(Bebchick, Lisa)
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Filing 10
NOTICE OF APPEARANCE by David B. Hennes on behalf of Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas..(Hennes, David)
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Filing 9
ORDER: Due to a technical error, the docket states that the above-captioned case was filed on November 23, 2022, when in fact it was filed on November 24, 2022. See ECF No. 1. Thus, it is hereby ordered that the filing date on the docket be corrected to November 24, 2022. SO ORDERED. (Signed by Judge Jed S. Rakoff on 11/30/2022) (kv) Transmission to Civil Case Openings Clerk for processing.
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***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #7 Proposed Order was reviewed and approved as to form. (km)
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Filing 8
NOTICE OF COURT CONFERENCE: Initial Conference set for 12/5/2022 at 09:30 AM in Courtroom 14B, 500 Pearl Street, New York, NY 10007 before Judge Jed S. Rakoff. (Signed by Judge Jed S. Rakoff on 11/29/2022) (kv)
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CASE ACCEPTED AS RELATED. Create association to 1:22-cv-02854-JSR. Notice of Assignment to follow. (vba)
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NOTICE OF CASE REASSIGNMENT to Judge Jed S. Rakoff. Judge Unassigned is no longer assigned to the case. (vba)
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Magistrate Judge Gabriel W. Gorenstein is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: #https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (vba)
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Filing 7
PROPOSED ORDER. Document filed by Jane Doe 1. Related Document Number: #4 ..(Edwards, Bradley) Proposed Order to be reviewed by Clerk's Office staff.
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***NOTICE TO ATTORNEY REGARDING DEFICIENT PROPOSED ORDER. Notice to attorney Bradley Edwards to RE-FILE Document No. #6 Proposed Order. The filing is deficient for the following reason(s): The case number is missing on the document. Re-file the document using the event type Proposed Order found under the event list Proposed Orders. (km)
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CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Unassigned. .(gp)
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CASE REFERRED TO Judge Jed S. Rakoff as possibly related to 1:22-cv-2854. (gp)
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Case Designated ECF. (gp)
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Filing 6
FILING ERROR - DEFICIENT DOCKET ENTRY - PROPOSED ORDER. Document filed by Jane Doe 1. Related Document Number: #4 ..(Edwards, Bradley) Proposed Order to be reviewed by Clerk's Office staff. Modified on 11/28/2022 (km).
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Filing 5
MEMORANDUM OF LAW in Support re: #4 MOTION For Leave to Proceed Anonymously re: #1 Complaint . . Document filed by Jane Doe 1..(Edwards, Bradley)
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Filing 4
MOTION For Leave to Proceed Anonymously re: #1 Complaint . Document filed by Jane Doe 1..(Edwards, Bradley)
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Filing 3
STATEMENT OF RELATEDNESS re: that this action be filed as related to 1:22-cv-02854. Document filed by Jane Doe 1..(Edwards, Bradley)
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Filing 2
CIVIL COVER SHEET filed..(Edwards, Bradley)
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Filing 1
COMPLAINT against Deutsche Bank AG New York Branch, Deutsche Bank Aktiengesellschaft, Deutsche Bank Trust Company Americas. (Filing Fee $ 402.00, Receipt Number ANYSDC-27003360)Document filed by Jane Doe 1..(Edwards, Bradley)
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