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Case 1:20-cr-00330-PAE Document 734-1 Filed 07/15/22 Page5of7 extensive measures to safeguard the confidentiality and security of all information submitted to, maintained by, exchanged with and distributed by the Program. 12. With the express assurance of confidentiality, and without the formality of court proceedings or fear of exposure and cross examination, victims agreed to participate in the Program, let their guards down and share exceedingly intimate, private information. Claimants relied upon the express condition and assurances of confidentiality in agreeing to support the very existence of the Program, in deciding to participate in the claims process, and in submitting their claims and any other information to the EVCP. They were willing to trust this process, despite deep-seated distrust of purported systems of “justice,” because of Program confidentiality. 13. Compromising confidentiality in any way would eviscerate the very foundation and fabric of the EVCP, and would have a disastrous chilling effect on victims who are already loath to disclose such personal information. The idea that the information the victims agreed to disclose to the EVCP solely for purposes of evaluation and potential resolution of the claim would be disclosed to anyone outside the EVCP for any other purpose is anathema to the integrity of this Program and others like it. The Program and Protocol were approved by a court order from the Probate Court in the U.S. Virgin Islands and I abided by the terms and guiding principles of the Protocol in every way and at every step of the process. Failing to abide by any term of the Protocol, much less the keystone condition of confidentiality, is intolerable, impermissible, and would lead to the unraveling of the Program. Allowing any disclosure of any documents, information and/or communications submitted to, maintained by, or exchanged with the EVCP would turn the Program on its head with far-reaching consequences to this victim population and beyond. DOJ-OGR-00011471