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Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page 7 of 16 November 19, 2021 Page Seven administrator of a program like the EVCP was required to disclose materials like those Maxwell seeks here.*° D. The EVCP’s Success As of August 2021, when the EVCP announced that it had concluded its claimant-facing operations, the EVCP had awarded nearly $125 million to approximately 150 eligible claimants; ninety-two percent of eligible claimants accepted their offers, and the EVCP paid over $121 million to those claimants.*° The EVCP received about 225 claims, which far exceeded the original expectation of about 100 claims.*” E. Procedural History In April 2021, Maxwell sought authorization to subpoena the law firm Boies Schiller for materials it submitted to EVCP on behalf of certain claimants. This Court denied the request, finding that Maxwell appeared to seek the materials for impeachment purposes, and that “the mere fact that certain documents might be impeachment evidence does not render them ‘relevant’ for purposes of Rule 17(c); if at all, those documents would become relevant only after a witness testifies.”°* The Court also held that Maxwell “may renew her request for these documents once she identifies specific individuals whose submissions she seeks and spells out with specificity the relevance of all requested materials. At that time, the Court will determine whether it is proper to require production of these materials to the Court so that the information 35 Ex. A § 14 (Feldman Decl.); see also Ex. H at 180:23-182:8 (testimony of Mr. Feinberg noting that, in his forty years of experience, no law enforcement agency had sought materials from a program and, invoking his experience with the compensation programs to resolve sexual abuse claims against the Catholic church, cautioning against attempts to obtain claimant information when “individual victims have participated in a program on the absolute guarantee of the administrator that information that have been submitted will not be disclosed to anybody”). 36 Ex. F at 1 (8/9/21 Press Release). 37 Ex. F at 1 (8/9/21 Press Release). 38 Order, dated Apr. 27, 2021, at 7 (ECF No. 252). DOJ-OGR-00011457