Case 1:19-cv-08673-KPF-DCF Document 42-4 Troutman Sanders LLP 875 Third Avenue New York, New York 10022 troutman.com Filed 01/10/20 Page 1 of 3 troutmarir sanders Bennet J. Moskowitz bennet.moskowitz©troutman.com December 3, 2019 E-MAIL Sigrid S. McCawley, Esq. Boies Schiller Flexner LLP 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 Re: Estate of Jeffrey E. Epstein Dear Ms. McCawley: We write in response to your letter dated November 22, 2019, posing two inquiries concerning the proposed Epstein Victims' Compensation Program (the "Program") presented by the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate") on November 14, 2019 to the Superior Court of the United States Virgin Islands (the "USVI Court") for approval. Our response does not constitute the Co-Executors' position regarding discovery (e.g., whether discovery is appropriate at this time or the information you requested is discoverable in the actions pending in the Southern District of New York); rather, we respond in order to further the parties' discussions concerning the Program. Accordingly, we repeat your inquiries below and address them to the best of our ability based on currently available information. 1. "What is the total value of Epstein's Estate?" The total assets held by the Estate are a matter of public record: the Co-Executors' Petition for Probate and for Letters Testamentary, filed on August 19, 2019 in the United States Virgin Islands, valued the Estate's assets in excess of $577 million. However, the Estate is subject to substantial potential liabilities in an undetermined amount, which makes it impossible to accurately calculate the total value of the Estate. Among other things, (i) the Estate is subject to estate taxes in at least two jurisdictions, the United States and France; (ii) the United States Department of Justice has indicated that it may seek civil forfeiture of properties held by the Estate; and (iii) your clients and other claimants