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ASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/
n Agreement [“NPA”] between the United States and Epstein? By filing this response, the United States does
oes the United States take any position regarding Defendant Epstein’s performance of his obligations pursuant to the
ng the position of the United States on Defendant Jeffrey Epstein’s Motion to Stay Proceedings [DE 99]. Fo
ability claim. See Lot 5, 23 F.3d at 364 (“Thus, Claimant’s assertion that only her own testimony could vin
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ___
of the civil proceedings in the “interests of justice” until the “expiration” of the Non- Prosecution Agreement [“NPA”] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of any
oes the United States take any position regarding Defendant Epstein’s performance of his obligations pursuant to the
ng the position of the United States on Defendant Jeffrey Epstein’s Motion to Stay Proceedings [DE 99]. Fo
ed out the wealth of evidence other than the defendant’s testimony that could be used to defeat a liability claim. See Lot 5, 23 F.3d at 364 (“Thus, Claimant’s assertion that only her own testimony could vindicate her is groundless; other participants to the illegal acts that gave rise to the forfeiture we
Program") is a voluntary, independent Program that has been established to compensate and resolve the claims of victims/survivors of sexual abuse by Jeffrey Epstein ("Epstein"). The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims administration experts Kenneth
ntary, independent Program that has been established to compensate and resolve the claims of victims/survivors of sexual abuse by Jeffrey Epstein ("Epstein"). The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims administration experts Kenneth R. Feinber
he claims of victims/survivors of sexual abuse by Jeffrey Epstein ("Epstein"). The Estate of Jeffrey Epst
that the individual acted under duress as a result of her own sexual abuse by Epstein, provided that other eligibility criteria are met. • If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with prejudice any existing lawsuits or legal actions or claims filed against
s the minor's legal representative; (2) in the case of an incompetent or legally incapacitated Claimant, a person who has been duly appointed as the Claimant's legal representative in accordance with applicable law; or (3) an attorney authorized to represent the Claimant for purposes of pursuing a claim
refers to any submission to the Epstein Victim's Compensation Program made by an Accuser, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their Attorneys, and any compensation received by an Accuser. INSTRUCT
ntary, independent Program that has been established to compensate and resolve the claims of victims-survivors of sexual abuse by Jeffrey Epstein ("Epstein"). The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims administration experts Kenneth R. Feinber
aine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca, Haddon, Morgan & Foreman P.C., 150 E
that the individual acted under duress as a result of her own sexual abuse by Epstein, provided that other eligibility criteria are met. • If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with prejudice any existing lawsuits, legal actions or claims filed against th
isions of the Administrator are not subject to review or modification in any way by the Estate or any other party or entity. 4. How much money from Jeffrey Epstein's Estate is available to the Program? There is no cap or limitation on the aggregate amount of funds available to compensate all eligible Claimants o
whether the claim is time-barred by the applicable statute of limitations, and whether they have previously filed a lawsuit against or settled with Epstein and/or the Estate. 2. If the Administrator determines that I am eligible to participate in the Program, does that mean that the Administrator has
n VCP") FOR VICTIMS-SURVIVORS OF SEXUAL ABUSE BY JEFFREY EPSTEIN Administrator FREQUENTLY ASKED QUESTIO
t to the Program could constitute a breach of the terms of the agreement. To address those concerns, the Estate has agreed to produce a copy of the Claimant's settlement agreement to the Program provided that the Claimant, or counsel acting on the Claimant's behalf, consents in writing to the Estate's p
refers to any submission to the Epstein Victim's Compensation Program made by an Accuser, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their Attorneys, and any compensation received by an Accuser. INSTRUCT
ntary, independent Program that has been established to compensate and resolve the claims of victims-survivors of sexual abuse by Jeffrey Epstein ("Epstein"). The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims administration experts Kenneth R. Feinber
aine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca. Haddon, Morgan & Foreman P.C., 150 E
that the individual acted under duress as a result of her own sexual abuse by Epstein, provided that other eligibility criteria are met. • If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with prejudice any existing lawsuits, legal actions or claims filed against th
refers to any submission to the Epstein Victim's Compensation Program made by an Accuser, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their Attorneys, and any compensation received by an Accuser. INSTRUCT
ntary, independent Program that has been established to compensate and resolve the claims of victims-survivors of sexual abuse by Jeffrey Epstein ("Epstein"). The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims to design the Program. Ms. will also se
aine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca. Haddon, Morgan & Foreman P.C., 150 E
that the individual acted under duress as a result of her own sexual abuse by Epstein, provided that other eligibility criteria are met. • If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with prejudice any existing lawsuits, legal actions or claims filed against th
Entities connected to both Jeffrey Epstein and Claimant

Ghislaine Maxwell
PERSON
United States
LOCATIONSouthern District
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSON
A. Marie Villafana
PERSON
Denver
LOCATION
Colorado
LOCATIONJeffrey Pagliuca
PERSON
Lauderdale
LOCATIONthe Eleventh Circuit
ORGANIZATIONWright
PERSONHaddon
PERSON
Foley Square
LOCATIONFeldman
PERSONThe First Circuit
ORGANIZATIONJenne
PERSON
Camille S. Biros
PERSON
Kenneth R. Feinberg
PERSON