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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.
Page: EFTA00010228 →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
Page: EFTA00010228 →ar mail, email, text message, memorandum, or other written communication of information of any kind. 5. "EVCP Material" 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
Page: EFTA00010228 →rogram") 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'. Kenneth R. Fei
Page: EFTA00010231 →aine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca, Haddon, Morgan & Foreman P.C., 150 E
Page: EFTA00018194 →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
Page: EFTA00018197 →ar mail, email, text message, memorandum, or other written communication of information of any kind. 5. "EVCP Material" 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
Page: EFTA00018197 →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
Page: EFTA00018200 →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
ar mail, email, text message, memorandum, or other written communication of information of any kind. 5. "EVCP Material" 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
he Defendant identified five individuals who require notice, but the Subpoena appears to seek personal and confidential information about all of the Epstein victims that BSF represents, which is more than five individuals. Thus, in an abundance of caution, BSF will notify each of the Epstein victims it
Defendant with two counts of jury for lying under oath during a civil deposition in a defamation action brought by when asked if she was aware of Jeffrey Epstein's sex trafficking scheme and whe er s e a ever iven Minor Victim-2 a massage. BSF represents Minor Victim-2 i and but does not represent and has ne
ction brought by when asked if she was aware of Jeffrey Epstein's sex trafficking scheme and whe er s e
file and is accurately described as a fishing expedition."). Similarly, Request 12 asks for "EVCP Material," which is defined as "any submission to the Epstein Victim's Compensation Program made by You, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed
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
ar mail, email, text message, memorandum, or other written communication of information of any kind. 5. "EVCP Material" 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
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
ar mail, email, text message, memorandum, or other written communication of information of any kind. 5. "EVCP Material" 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
Entities connected to both Jeffrey Epstein and the Epstein Victim's Compensation Program

Ghislaine Maxwell
PERSON
United States
LOCATIONSouthern District
LOCATION
Denver
LOCATION
Colorado
LOCATIONJeffrey Pagliuca
PERSONHaddon
PERSON
Foley Square
LOCATIONFeldman
PERSON
Camille S. Biros
PERSON
Kenneth R. Feinberg
PERSONAccusers
ORGANIZATIONJordana H. Feldman
PERSON
Marci A. Hamilton
PERSONHADDON, MORGAN & FOREMAN P.C.
ORGANIZATIONClaimant
PERSONB. Legal Representatives of Claimants
ORGANIZATIONOffice of the District Attorney
ORGANIZATIONMorgan & Foreman P.C.
ORGANIZATIONthe Epstein Victim's
ORGANIZATION