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Epstein ("Epstein"). The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims administration experts Kenneth R. Feinberg, Camille S. Biros and Jordana H. Feldman to design the Program. Ms. Feldman will also serve as the Administrator of the Program (the "Administrator"
tted by each Accuser, not limited to Claim Forms and supporting submissions made by each Accuser; 2. Communications between the EVCP to each of the Accusers and/ or their Attorneys; 3. Copies of any payments to the Accusers and their Attorneys; 4. Any and All Releases executed by the Accusers. EFTA0004
Estate is being probated) to create a voluntary claims resolution program for victims of Epstein's sexual abuse.' The program's design was led by Kenneth R. Feinberg, and Camille S. Biros—all nationally recognized claims-administration experts.' Mr. Feinberg is the nation's leading expert in crafting effective d
ative support" that the administrator may consider in evaluating claims." Maxwell also mischaracterizes the Protocol when she says that it "rewards Accusers who have filed a lawsuit, legal action or claim of sexual abuse."18 This is inaccurate. As the Protocol makes clear, the existence of "lawsuit[s], l
col, I testified in open court in the Probate Court in the U.S. Virgin Islands about the confidentiality requirement imposed on the Program, as did Kenneth R. Feinberg, who was a Co-Designer of the EVCP. A copy of relevant excerpts of the transcript is attached to the motion as Exhibit H, and the relevant testimony
alysis 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 ("Epstein"). The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims administration experts Kenneth R. Feinberg, Camille S. Biros and to design the Program. will also serve as the Administrator of the Program (the "Administrator"). This Protocol reflects in
tted by each Accuser, not limited to Claim Forms and supporting submissions made by each Accuser; 2. Communications between the EVCP to each of the Accusers and/ or their Attorneys; 3. Copies of any payments to the Accusers and their Attorneys; 4. Any and All Releases executed by the Accusers. EFTA0009
Entities connected to both Kenneth R. Feinberg and Accusers

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Camille S. Biros
PERSONFeldman
PERSONMartin Weinberg
PERSON
United States
LOCATIONDarren Indyke
PERSON
Colorado
LOCATIONJeffrey Pagliuca
PERSON
Department of Justice
ORGANIZATION
David Boies
PERSON
Marci A. Hamilton
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
United States Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Kaplan
PERSON
Southern District of New York
ORGANIZATIONSouthern District
LOCATIONB. Legal Representatives of Claimants
ORGANIZATION