Case 1:22-cv-10019-JSR Document 248-1 Filed 10/23/23 Page 1 of 5 October 19, 2023 Hand Delivery Honorable Jed S: Rakoff Daniel Patrick Moynihan United States Courthouse 500 Pearl Street Room 1340 New York, NY 10007 Re: Doe v. JPMorgan Chase Bank, N.A., No. 1:22-CV-10019 (S.D.N.Y.) Dear Judge Rakoff: The Attorneys General of New Mexico, Arizona, California, Connecticut, Delaware, the District of Columbia, Hawaii, Illinois, Maryland, Minnesota, Mississippi, New York, Oregon, Pennsylvania, Tennessee, Utah, and Vermont write concerning the proposed settlement in Doe v. JPMorgan Chase Bank, N.A., No. 1:22-CV-10019 (S.D.N.Y.) because it contains language that purports to release state Attorney General parens patriae claims under Section 1595(d) of the Trafficking Victims Protection Act ("TVPA") for damages on behalf of trafficking victims. The Class Action Fairness Act of 2005 requires that settlement defendants in a class action serve notice of the settlement on the appropriate state officials, thereby giving them an opportunity to review and respond to the settlement prior to its approval. The legislative history of CAFA establishes "that notice of class action settlements be sent to appropriate state and federal officials ... so that they may voice concerns if they believe that the class action settlement is not in the best interests of their citizens." S. REP. 109-14, 2005 U.S.C.C.A.N. 3, 6. Case law also recognizes this role of state Attorneys General. See, e.g., Figueroa v. Sharper Image Corp., 517 F. Supp. 2d 1292, 1301 n.9 (S.D. Fla. 2007) (noting role of Attorneys General in class settlement approval process); True v. American Honda Motor Co., 749 F. Supp. 2d 1052, 1082 (C.D. Cal. 2010) (discussing views of state Attorneys General with respect to class action settlement grounded in products liability claims). Since the passage of the Act, state Attorneys General have successfully objected to or brought about the modification of settleme