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Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page4of16 November 19, 2021 Page Four 2020, the U.S. Virgin Islands probate court approved the EVCP as designed.'* On June 25, 2020, the EVCP announced that individuals could begin the process of filing claims.!° In her motion seeking approval for the subpoena, Maxwell makes at least two mischaracterizations of the Protocol for evaluating a claimant’s eligibility for compensation. First, she says that the Protocol “credits” victims “who have had charges filed against Epstein or any employee of Epstein.”!© The Protocol does no such thing. It simply identifies the existence of any information or findings of law enforcement as one factor to be considered, as part of a non-exhaustive list of “appropriate factors and corroborative support” that the administrator may consider in evaluating claims.!7 Maxwell also mischaracterizes the Protocol when she says that it “rewards Accusers who have filed a lawsuit, legal action or claim of sexual abuse.”!® This is inaccurate. As the Protocol makes clear, the existence of “lawsuit[s], legal action[s] or claim[s]” was used to identify individuals as potential victims to send them claim forms.'? Individuals who had not previously filed a lawsuit, legal action, or claim were also invited to register a claim with the EVCP.”° B. Key Features of the EVCP The EVCP was designed with non-exclusive “key features” to provide “an efficient and fair resolution of claims” on a “voluntary, non-adversarial, [and] confidential” basis.?! For example, the EVCP operates “entirely free from any interference or control by the Epstein ‘4 Ex. G (order of the Superior Court of the Virgin Islands Division of St. Thomas and St. John, dated June 2, 2020); see Ex. A ¥f 8, 13 (Feldman Decl.). 'S Ex. C (6/25/20 Press Release). ‘6 Maxwell’s Mot. for an Order Authorizing a Subpoena Pursuant to Fed. R. Crim. P. 17(c)(3), dated Nov. 14, 2021 (“Maxwell Mot.”), at 3, 5. '7 Ex. D at 5-6 (Protocol); see Ex. A § 16 (Feldman Decl.). '8 Maxwell Mot. at 3, 5. '9 Ex. D at 4 (Protocol); see Ex. A 4 16 (Feldman Decl.). 20 Ex. D at 4 (Protocol). 71 See https://www.epsteinvep.com/; see also Ex. D at 1-2 (Protocol). DOJ-OGR-00011454