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Case 1:20-cr-00330-PAE Document 734-1 Filed 07/15/22 Page3of7 sentiment, a sentiment that was also conveyed to me personally, repeatedly and pleadingly by the victims themselves. 8. With that confidentiality imperative in mind, we designed the EVCP Protocol with input and support from the victims’ lawyers, the Attorney General of the U.S. Virgin Islands, the Epstein Estate and other interested parties. The Protocol was approved by the Probate Court of the U.S. Virgin Islands (where Epstein’s estate is being probated); a copy of the court order is included with this motion as Exhibit G. The Protocol sets out the terms, conditions and guiding principles that govern the Program, the claims process and my role and responsibilities as independent Administrator. In accordance with the Protocol, I had complete and exclusive autonomy and decision-making authority over all claim determinations and all claim procedures. The Estate agreed to pay whatever amounts I determined in my independent judgment to eligible claimants in exchange for the claimant releasing the Estate and other related individuals and entities from any civil claims relating to the allegations of sexual abuse. The Protocol, as well as other information about the EVCP, is publicly available on its website at https://epsteinvep.com/, and the Protocol is attached to the motion as Exhibit D. 9. Confidentiality is an indispensable condition of the EVCP; its importance cannot be overstated. The EVCP Protocol expressly requires confidentiality in order to protect the privacy of claimants. In accordance with the Protocol, information provided to or obtained by the Program was used by me, in my role as Administrator, for the sole purpose of processing and evaluating claims and performing other Program-related work (such as resolution of any related Medicaid and/or Medicare liens). It was otherwise kept - and must remain - confidential. The Protocol provides that the Program’s files are not available for inspection or review at any time, and that no information obtained solely through the Program will be disclosed publicly or used DOJ-OGR-00011469