This action is likely to involve contested and serious questions of law and fact, such that the value of immediate monetary recovery, in conjunction with the value of the prospective relief set forth in the Settlements, outweigh the uncertain possibility of future relief after protracted and expensive litigation; and Paragraph 2(bb) of the Settlement Agreements defines "OTC Class Member" as: "A Person who is a member of the OTC Class and has not timely and validly excluded himself, herself, or itself in accordance with the procedures established by the Court."

Pursuant to paragraph 2(ii) of the Deutsche Bank Settlement Agreement "Released Parties" are defined as: "Deutsche Bank and each of its past or present direct and indirect parents (including holding companies), subsidiaries, affiliates, associates (all as defined in SEC Rule l 2b-2 promulgated pursuant to the Securities Exchange Act of 1934), predecessors, successors, and each of their respective officers, directors, employees, agents, attorneys, legal or other representatives, trustees, heirs, executors, administrators, advisors, and assigns.

Pursuant to paragraph 2(jj) of the HSBC Settlement Agreement "Releasing Parties" are defined as: "Individually and collectively, Class Plaintiffs and each OTC Class Member, on behalf of themselves and any of their respective past or present officers, directors, stockholders, agents, employees, legal representatives, partners, associates, trustees, beneficiaries, beneficial owners, parents, subsidiaries, divisions, affiliates, heirs, executors, administrators, purchasers, predecessors, successors, and assigns, whether or not they

To the extent permitted by law, the Court bars claims against the Released Parties for contribution or indemnification (however denominated) for all or a portion of any amounts paid or awarded in the OTC Action by way of any settlement, judgment or otherwise by any of the following:

To the extent permitted by law, the Court bars claims by the Released Parties for contribution or indemnification (however denominated) for all or a portion of any amounts paid or awarded in the OTC Action by way of any settlement, judgment or otherwise against any of the following:

United States Attorney Southern District of New York

The Honorable Vernon S. Broderick United States District Judge Thurgood Marshall United States Courthouse, Room 415 40 Foley Square New York, New York 10007 Re: The Silvio J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007 September 27, 2018 United States v. John W. Ashe, et al., 15 Cr.

Dear Judge Broderick: The Government respectfully writes, with the consent of counsel to Fairfax Media Limited and the Australian Broadcasting Corporation (together, the “News Organizations”), to request that the deadline for the Government to respond to the letter motion of the News Organizations, dated August 29, 2018 (Docket Entry No. 857), be adjourned by two weeks, from September 28, 2018, to October 12, 2018.

Counsel for the Government and counsel for the News Organizations have conferred regarding the request of the News Organizations for certain material, and the Government expects that the parties will reach a resolution that will moot, or whole or in large part, the need for the Court rule on the letter motion, but more time is needed to reach such a resolution.

Acting Chief, Fraud Section Criminal Division

706 (VSB) WHEREAS, on or about October 26, 2015, Ng Lap Seng, a/k/a “David Ng," the defendant, through counsel, posted $20,000,000 (the “Bail Funds”) in connection with satisfying the conditions of release pending trial in this matter, and the bulk of the Bail Funds remain on deposit with the Clerk of Court (receipt number 465401137538); WHEREAS, on or about July 27, 2017, the defendant was convicted following a trial by jury on all counts in Superseding Indictment SS 15 Cr.

the Government has moved pursuant to Title 28, United States Code, Section 2044 that the Bail Funds be applied toward the payment of these sums;

the defendant through counsel, consents to the Government’s motion, and has agreed to have any remaining Bail Funds returned to Kirkland & Ellis LLP; IT IS HEREBY ORDERED that:

The remainder of the Bail Funds (after transfer of $1,303,577.20, plus applicable interest, to satisfy the defendant’s outstanding restitution, special assessment, and fine obligations), shall be released to an interestmbearing, segregated client account designated by Kirkland & Ellis LLP.

The Clerk of the Court shall forward three certified copies of this Order to Assistant United States Attorney Alexander Wilson, Chief of the Money Laundering and Asset Forfeiture Unit, One St. Andrew’s Plaza, New York, New York, 10007.