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Case 1:20-cr-00330-PAE Document 734-1 Filed 07/15/22 Page7 of 7 that I considered in evaluating claims. One of those factors was “Whether there exists any information and/or pertinent findings offered by the appropriate Office of the District Attorney, United States Attorney’s Office, or other law enforcement agency.” (Protocol at 5-6.) The Protocol does not use the term “credit” nor does it address what weight, if any, is afforded to such information in the context of an individual claim. That is because there was no formula or point system or quantifiable “credit” for this factor or any other factor in the determination of individual claims. Claims were evaluated on a highly individualized analysis based on a host of factors and the overall totality of the circumstances. Ms. Maxwell’s motion also states that “t]he Protocol also rewards Accusers who have filed a lawsuit, legal action or claim of sexual abuse against Epstein, or the Estate, which includes any employees or former employees of Epstein.” This too is inaccurate. When the Protocol refers to an individual’s “lawsuit, legal action or claim,” it does so in the context of identifying individuals prior to the Program’s launch to whom the program would be sending claim forms, because, on the basis of such lawsuits or claims, the program could identify them at the outset as potential claimants. (Protocol at 4.) The Protocol also indicates that individuals who had not filed a lawsuit or claim could also register to participate in the program, and, if my preliminary review determined that they were eligible to participate, these individuals too would be sent claim forms. The fact that this language falls under the “Claims Submission Process” section of the Protocol and not the “Claims Evaluation and Determination” section demonstrates the purpose for which it was included. I declare under the penalty of perjury that the foregoing is true and correct. Dated: November 19, 2021 By:Geidana WN. Feldman ordana H. Feldman DOJ-OGR-00011473