DOJ-OGR-00007361.jpg

Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page4of9 and obtain by any means" individuals who were under the age of 18, including Accuser-4, "who were then caused to engage in at least one commercial sex act with Jeffrey Epstein." (Id. §] 27). Both counts are based on the allegations of Accuser-4 and allege conduct that purportedly occurred "[f]rom at least in or about 2001, up to and including in or about 2004." (/d. 9 23, 27). B. The Accusers and The Epstein Victim Compensation Fund es Rn Vs. Maxwell was not mentioned in that lawsuit. Accuser-4 and Witness-3 applied to the Epstein Victim Compensation Fund. All four women chose to accept compensation from the Epstein Victim Fund. In its 3500 disclosures, the government has provided statements from the Accusers indicating xy OO e—CSCSC‘SSC The Protocol for receiving compensation is attached as 1 to Attachment A. The Protocol requires a written submission. The claims are evaluated per the Protocol which credits “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.” Accordingly, the Protocol credits claimants who have had charges filed against Epstein or any employee of Epstein. The June 2019 indictment against Epstein did not include the allegations of the four Accusers that are contained in the S2 Indictment charging Ms. Maxwell. Under the terms of the Protocol, the Accusers here, and their civil lawyers, stood to benefit if the prosecution against Ms. Maxwell went forward. The 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. Lawyers for DOJ-OGR- 00007361