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Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page4of8 Page 4 C. Any and All Material Submitted to the EVCP The defendant makes a further request for any and all submissions by the Minor Victims to the EVCP. This request would not generate relevant, admissible evidence for two reasons. First, the defendant has not identified a theory by which these materials are relevant and admissible. The defendant argues primarily that the materials contain relevant impeachment information because “[f]ull and complete cross-examination is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Maxwell, as well as others.” (Def. Mot. at 6). Materials are not relevant and admissible at trial, as required by Nixon, simply because they aid the defendant’s “understanding.” And the defendant articulates only one theory by which EVCP materials may be admitted to show bias. According to the defendant, the May 2020 Protocol governing the EVCP states that claims are evaluated depending on whether “there exists any information and/or pertinent findings offered by the appropriate ... United States Attorneys’ Office or other law enforcement agency.” (Def. Mot. at 5). If this “prosecution against [the defendant] went forward,” the argument goes, the Minor Victims and their lawyers would “benefit.” (/d.) The defendant already has the information relevant to this argument. She has the protocol for the EVCP. The Government has “offered” no “information” or “findings” to the EVCP about the Minor Victims; to the extent the EVCP relied on publicly available information about this case to make its determination, such as the charging instruments in this case, that information is in the public record. And the Government has already disclosed to the defendant the settlement DOJ-OGR-00007396