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Case 1:20-cr-00330-PAE Document 480 Filed 11/21/21 Page6éof9 the government has provided statements form the Accusers indicating yy OO e—CSSC‘C‘(C(Cs FC The Protocol for receiving compensation is attached as Exhibit 1 to Attachment A. The Protocol requires a written submission. The claims are evaluated per the Protocol which credits “Tw ]hether 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 were instrumental in creating and structuring the terms of the Protocol. 3x i e—CSCSCSCsis SCS The documents sought are obviously relevant -- statements of the Accusers about what they claim happened for purposes of securing a settlement. Similarly, the amount of compensation is also relevant. "Relevant evidence means evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence.” United States v. Malpeso, 115 F.3d 155, 162-63 (2d Cir. 1997) (quoting Fed. R. Evid. 410). DOJ-OGR-00007363