This is the website of Simone K. Lelchuk, the Fund Administrator of the SDNY Settlement Fund 2026. This website contains important information about a settlement (the “Settlement”) of Doe 3 v. Indyke, et al., currently pending in the United States District Court for the Southern District of New York, Case No. 1:24-CV-01204 (AS). The Court has appointed Simone K. Lelchuk as Fund Administrator for the Settlement.

All capitalized terms not otherwise defined on this website meanings set forth in the Settlement Agreement dated February 19, 2026. To the extent there is any conflict between the definitions of capitalized terms on this website and the Settlement Agreement, the definition in the Settlement Agreement controls. A copy of the Settlement Agreement is available on this website under the Important Documents page.

The Proposed Settlement

The proposed Settlement of the Litigation, as set forth in the Settlement Agreement, provides for (1) $35,000,000 in cash, if there are 40 or more eligible class members, or $25,000,000 in cash, if there are fewer than 40 eligible class members; (2) entry of a Judgment as provided under the Settlement Agreement, dismissing the Litigation with prejudice; (3) awarding Boies Schiller Flexner LLP attorneys’ fees, costs, and expenses out of the Global Settlement Account (as defined in the Notice of Proposed Settlement of Class Action (“Notice”)); and (4) awarding the Named Plaintiffs who, in this Litigation, did not voluntarily dismiss their claims, an incentive award out of the Global Settlement Account. The Court will hold a hearing on September 16, 2026, at 2:00 p.m., before the Honorable Arun Subramanian at the United States District Court for the Southern District of New York, Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, NY, 10007 to determine whether the proposed settlement is fair, reasonable, and adequate and to approve the Plan of Allocation as fair, reasonable, and adequate.

Who is a “Class Member”?

If you were sexually assaulted, abused, or trafficked by Jeffrey Epstein (“Epstein”) and/or anyone associated with Epstein during the period between January 1, 1995 and August 10, 2019 AND you have not previously executed a settlement that included a release of the Epstein Estate, you are a “Class Member” and your rights are affected by the Settlement. Please carefully review this website in its entirety as it explains the claims process to participate in a distribution of the net proceeds from the Settlement, how to opt-out of the Settlement, and certain deadlines related to the Settlement.

How do I Participate in the Settlement?

To share in the distribution of the Net Settlement Fund, you must establish your rights by submitting a Questionnaire and Release, online by no later than May 12, 2026 11:59PM EDT or by mail so as to be postmarked by no later than May 12, 2026. If you previously settled as part of the Epstein Victims’ Compensation Program or settled a claim with the Epstein Estate privately, then you are ineligible to participate in this Settlement.  If you have questions about your eligibility, you may reach out to Class Counsel. Your failure to submit a Questionnaire and Release by May 12, 2026, 11:59PM EDT will result in the rejection of your claim and preclude you from receiving any recovery in connection with the Settlement of this Litigation. The Questionnaire and Release is available in English, Russian, and French and can be located under the Important Documents page on this website. Please contact the Fund Administrator if you want the Questionnaire and Release in a different language.

What if I want to exclude myself from the Settlement?

To exclude yourself or opt-out of the Settlement and preserve your claims related to the Litigation, you must send a signed letter by First-Class mail saying that you want to be excluded from the Class in the following Litigation: Ward v. Indyke, et. al., No. 1:24-CV-01204 (AS). Be sure to include your name, address, and telephone number. Your exclusion request must be postmarked by no later than April 13, 2026, and sent to the Fund Administrator at Simone K. Lelchuk, Resolution Services LLC, c/o FREJKA PLLC, 415 East 52nd Street | Suite 3, New York, New York 10022.

Meetings with the Fund Administrator

As part of the process, you may (but are not required to) request a video or in-person (in New York City) meeting with the Fund Administrator. The Fund Administrator may request a meeting with some, but not all Class Members, if she feels a meeting will help her obtain additional, helpful information about a person’s claim.

Submission of a Questionnaire and Release is Not a Guaranty of an Allocation

Submitting a Questionnaire and Release does not guarantee that you will receive an allocation from the Net Settlement Fund. The Fund Administrator will ultimately determine whether a person will receive an allocation and, if so, the amount.

Medical Liens

As a mandatory part of the Fund administration process, the Fund Administrator will confirm that there are no medical liens related to your injury that must be repaid prior to disbursement of funds to you. The Fund Administrator will confirm that there are no healthcare liens asserted against you related to an injury covered by the settlement with respect to:

• Medicare Parts A and B;
• Medicare Parts C and D, including private insurance companies that administer Medicare Parts C and D coverage;
• State Medicaid; and
• Military benefits (TRICARE or Veterans Affairs).

Federal and state law give Medicare, Medicaid, the U.S. Department of Veterans Affairs, TRICARE and other governmental agencies a right to recover some or all of a settlement payment as reimbursement if they paid for medical care related to an injury that is covered by a settlement. The Fund Administrator cannot accept your representation that there are no medical liens asserted by these entities and must instead independently verify whether there are medical liens. If it is determined that there is a medical lien, the Fund Administrator’s medical lien resolution specialists will review the lien and attempt to negotiate a resolution with the lien holder on your behalf. Any lien amount that must be paid will affect the size of a disbursement of funds to you.

Does a bankruptcy prevent me from being a “Class Member”?

As part of the Questionnaire and Release, you must indicate whether you have filed for bankruptcy or had an involuntary bankruptcy petition filed against you at any time between the date of your interactions with Epstein and the date the Questionnaire and Release is submitted. You should contact your bankruptcy counsel or Class Counsel to understand how to proceed but this does not prevent you from being a “Class Member” or submitting a Questionnaire and Release.

Protecting Your Privacy.

Your identity and all information you provide in making your claim will be kept strictly confidential to the maximum extent permitted by law. Everyone you interact with when making your claim – either online or on the phone – is specially trained to be sensitive to the needs of survivors, and to ensure you have a safe, private, and compassionate place to tell your story.

I need more information.

More information about the Settlement, including the Questionnaire and Release, deadlines, excluding yourself, and objecting to the Settlement, can be found on the Frequently Asked Questions page of this website and by watching the video at the bottom of this page.

What if I still have questions?

If you have any legal questions, including whether you are a “Class Member” or regarding the Settlement, you may contact Class Counsel by email at epsteinsettlement@bsfllp.com and by telephone at 1-212-446-2300. If you have any questions regarding the claim process, you may contact the Fund Administrator by email at Claims@SDNYSettlementFund2026.com and by telephone at 1-212-641-0800.

In order to be eligible to receive payment from the Settlement as an Eligible Class Member, you must submit a Questionnaire and Release to the Fund Administrator. Questionnaires and Releases must be received through a secure, dedicated online portal no later than May 12, 2026 11:59PM EDT or mailed so as to be postmarked no later than May 12, 2026 by mailing the Questionnaire and Release and any supporting documentation to the Fund Administrator.

If you choose to exclude yourself from the Settlement, then you will get no payment. This is the only option that potentially allows you to ever be part of any other lawsuit against any of the Defendants or any other Released Defendant Parties about the legal claims being resolved by this Settlement. Should you elect to exclude yourself from the Class, you should understand that Defendants and the other Released Defendant Parties will have the right to assert any and all defenses they may have to any claims that you may seek to assert, including, without limitation, the defense that any such claims are untimely under applicable statutes of limitations and statutes of repose. Notices to opt-out of this Settlement must be in the form of a signed letter, mailed to the Fund Administrator via First-Class mail so as to be postmarked no later than April 13, 2026.

Write to the Court about why you do not like the Settlement. Objections must be received on or before August 26, 2026.

Ask to speak in Court about the fairness of the Settlement. Requests to speak must be received no later than August 26, 2026. If you submit a written objection, you may (but you do not have to) attend the hearing.

As a Class Member, you are not required to apply for an allocation from the Settlement.  You may instead choose to do nothing, and you will not receive any payment.  You will, however, still be a Class Member, which means that you give up your right to ever be part of any other lawsuit against the Defendants or any other Released Defendant Party about the legal claims being resolved by this Settlement and you will be bound by any judgments or orders entered by the Court in the Litigation.