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Case 1:20-cr-00330-PAE Document 734-1 Filed 07/15/22 Page4of7 by the Estate in defending itself from any claim, regardless of forum. And the Protocol expressly authorizes the destruction of Program files to protect the privacy of claimants participating in the Program. 10. —_ In addition to the Protocol, I testified in open court in the Probate Court in the U.S. Virgin Islands about the confidentiality requirement imposed on the Program, as did Kenneth R. Feinberg, who was a Co-Designer of the EVCP. A copy of relevant excerpts of the transcript is attached to the motion as Exhibit H, and the relevant testimony appears at pages 111:1-111:16, 118:9-118:24 (my testimony) and pages 170:25-171:25, 180:23-182:8 (Mr. Feinberg’s testimony). I posted FAQs on the EVCP website that address the scope and assurance of confidentiality. A copy of the EVCP FAQs is attached to the motion as Exhibit E (see Questions 5, 6 and 11). I also issued several press releases during the claims process that highlight confidentiality as a “cornerstone” of the EVCP and of “paramount importance.” Copies of EVCP press releases are attached as Exhibits B, C, and F. Through numerous public forums, confidentiality was discussed as a centerpiece of the Program. 11. The express condition of confidentiality significantly informed the way I administered the Program and approached the claims process. I implemented a trauma-informed process where claimants could share information freely and openly without feeling the need to censor themselves - not only about the events that gave rise to the claim but also the often profound impact on their lives. I spent months building trust and confidence in this alternative dispute resolution process among claimants and their attorneys — a process that was new and unfamiliar to many of them. I dispensed with formal rules of procedure or evidence that would apply in a court of law in favor of a less formal, non-adversarial approach. And I implemented DOJ-OGR-00011470