Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page1of16 Smith Villazor LLP 250 West 55th Street, 30th Floor New York, New York 10019 www.smithvillazor.com Patrick J. Smith [email protected] T 212.582.4400 SMITH | VILLAZOR November 19, 2021 BY E-MAIL to [email protected] The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Maxwell, No. 20 Cr. 330 Dear Judge Nathan: We represent Jordana H. Feldman, the independent, neutral administrator of the Epstein Victims’ Compensation Program (the “EVCP”). Pursuant to the Court’s memo-endorsement of our letter dated November 15, 2021, we respectfully move to quash defendant Maxwell’s subpoena directed to Ms. Feldman for certain documents of the EVCP concerning four victims. The EVCP is a court-approved, litigation-alternative program established to resolve confidentially claims of sexual abuse against Jeffrey Epstein, his Estate, and other related individuals and entities. Protecting the confidentiality of EVCP claimants’ information is a cornerstone of the program and essential to its success. In program documents, press releases, and on its website, the EVCP and Ms. Feldman repeatedly emphasized the program’s promise of confidentiality. That promise allowed for participation by victims who otherwise would have been reluctant to share their stories. It also encouraged victims to compromise claims that might otherwise have taken up substantial judicial resources. Only a confidential program can DOJ-OGR-00011451