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I. Background On October 11, 2021, the government began producing 3500 material to the defense. These rolling productions confirmed that the four Accusers referenced in the indictment applied for and received millions of dollars from the Epstein Victim Compensation Fund. Ms. Maxwell requests the Court
he claims are evaluated per the Protocol which credits "[w]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
I. Background On October 11, 2021, the government began producing 3500 material to the defense. These rolling productions confirmed that the four Accusers referenced in the indictment applied for and received millions of dollars from the Epstein Victim Compensation Fund. Ms. Maxwell requests the Court
he claims are evaluated per the Protocol which credits "[w]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
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
considered in evaluating claims. One of those factors was "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." (Protocol at 5-6.) The Protocol does not use the term "credit" nor doe
Entities connected to both Accusers and Office of the District

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONDarren Indyke
PERSON
Prince Andrew
PERSON
Cynthia Nixon
PERSONJeffrey Pagliuca
PERSON
Department of Justice
ORGANIZATION
Kenneth R. Feinberg
PERSON
Michael Cohen
PERSONthe Epstein Estate
ORGANIZATION
Camille S. Biros
PERSONMORGAN & FOREMAN
ORGANIZATION
Marci A. Hamilton
PERSONClaimant
PERSON
Brady
PERSONCohen & Gresser LLP
ORGANIZATIONthe Epstein Fund
ORGANIZATION
Kentucky
LOCATIONSedaghaty
PERSONthe Epstein Victim Compensation Fund
ORGANIZATION