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Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page5of16 November 19, 2021 Page Five Estate.”” The program is also “purely voluntary”; claimants’ rights are not impacted unless and until they accept an offer of compensation and execute a release.”*> Victims were also eligible to participate “regardless of where they were harmed, when they were harmed, whether the claim is time-barred by the applicable statute of limitations, and whether they have previously filed a lawsuit against or settled with Epstein and/or the Estate.”~4 And as critically relevant here, the EVCP is confidential.?> The EVCP and Ms. Feldman repeatedly emphasized the importance of confidentiality to the integrity of the program and the assurance that the EVCP would keep confidential victims’ participation in the program and any documents and other information submitted to, maintained by, exchanged with, or distributed by the program.*° Ms. Feldman’s probate-court testimony, the Protocol, the FAQs, the EVCP website, and EVCP press releases all highlight the program’s promise to maintain confidentiality of claimants’ information and how that promise is a “cornerstone” of the EVCP.”’ Victims relied upon the condition of strict confidentiality in agreeing to support the existence of the Program and in deciding to participate in the claims process.”* 2 See https://www.epsteinvep.com/; see also Ex. D at 1 (Protocol). 3 Ex. D at 1 (Protocol). 4 Ex. D at 2 (Protocol). 5 Ex. D at 2, 6, 8-9 (Protocol). 6 Ex. A ¥q 8-12 (Feldman Decl.). 27 See: e Ex. Hat 111:1-111:16, 118:9-118:24 (testimony). e Ex. D at 8-9 (Protocol section on “Confidentiality/Privacy”). e Ex. Eat 9 (FAQs no. 11). e https://www.epsteinvcp.com/ (website noting claimant privacy of “paramount importance’’). e Ex. C at 2 (6/25/20 Press Release noting claimant privacy of “paramount importance”). e Ex. F at 1 (8/9/21 Press Release noting confidentiality “critical to the success” and a “cornerstone” of the EVCP). 28 See Ex. A 4 7-8, 12 (Feldman Decl.). DOJ-OGR-00011455