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Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page6of16 November 19, 2021 Page Six C. The Critical Importance of Confidentiality to the EVCP and Similar Programs Ms. Feldman’s declaration explains why confidentiality is so critical to programs like the EVCP.”? As she notes, “it can be incredibly difficult for victims of sexual abuse to share such deeply personal, intimate, private information about their experiences and the impact it has had on their lives,” and many victims “suffer from a loss of trust and confidence in individuals in positions of authority.”°° The EVCP sought to create an environment where claimants did not feel a need to “censor themselves” about their experiences.*! Creating that environment simply would not be possible without strong assurances of confidentiality. As expressed to Ms. Feldman by victims’ attorneys and victims themselves, “many victims were initially reluctant to participate in the EVCP — or would have refused to participate — without an express assurance of confidentiality.”*? Any intrusion on that promise would threaten the foundation of the program. As Ms. Feldman explains, “[c]ompromising confidentiality in any way would eviscerate the very foundation and fabric of the EVCP, and would have a disastrous chilling effect on victims.”*? Compelling the EVCP to disclose the information it promised to keep confidential would be “anathema to the integrity of this Program and others like it” and “would turn the Program on its head with far-reaching consequences to this victim population and beyond”—meaning for the EVCP and the viability of other past, existing, and future litigation-alternative victim compensation programs.*4 Ms. Feldman is unaware of any other instance in which an ?9 See Ex. A 44 5-14 (Feldman Decl.). 30 Ex. A ¥ 6 (Feldman Decl.). 31 Ex. A §q] 8-12 (Feldman Decl.). 3? Ex. A § 7 (Feldman Decl.). 33 Ex. A § 13 (Feldman Decl.). 34 Ex. A §q 13-14 (Feldman Decl.). DOJ-OGR-00011456