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Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page5of9
were instrumental in creating and structuring the terms of the Protocol. Sec
i e—sSCSC‘(SSs
i —SSSCSCs
1. Specificity
The Protocol establishes a process that all claimants must follow. The “Claimant” must
submit a “Claim Form” with documentation. These claims are then evaluated based on the
criteria established in the Protocol. Any deficiencies in the claim are communicated to the
Claimant. If a claim is approved, the Administrator sends the Claimant an offer letter and a
release. Ms. Maxwell is requesting specific documents identified in the Protocol, including the
Claim Form with any supporting documentation, correspondence between the Claimant (or her
attorney) and the Administrator, a copy of the check issued to the Claimant, and a copy of the
release signed by the Claimant.
2. Admissibility
There are no evidentiary impediments to admissibility. The documents are relevant,
authentic, and an appropriate evidentiary foundation can be established under many rules of
evidence. The Claim Form is a prior statement of the Accusers about the events alleged in the S2
Indictment. The Claim Forms and subsequent communications are admissible impeachment
evidence at trial.
3. Relevance
As previously stated, lll
OO —SCSC‘CSCs
Dn is. Maxwell was not mentioned in that
lawsuit. Accuser-4 and Witness-3 applied to the Epstein Victim Compensation Fund. All four
women here chose to accept compensation from the Epstein Victim Fund. In its 3500 disclosures
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Dates
Document Details
| Filename | DOJ-OGR-00007362.jpg |
| File Size | 579.0 KB |
| OCR Confidence | 93.1% |
| Has Readable Text | Yes |
| Text Length | 1,543 characters |
| Indexed | 2026-02-03 17:22:21.104597 |