Epstein Secrets

York, New York 10007 Re: United States v. Maxwell. No. 20 Cr. 330 Dear Judge Nathan: We represent the independent, neutral administrator of the Epstein Victims' Compensation Program (the "EVCP"). Pursuant to the Court's memo-endorsement of our letter dated November 15, 2021, we respectfully move to

ing four victims. The EVCP is a court-approved, litigation-alternative program established to resolve confidentially claims of sexual abuse against Jeffrey Epstein, his Estate, and other related individuals and entities. Protecting the confidentiality of EVCP claimants' information is a cornerstone of the prog

ve confidentially claims of sexual abuse against Jeffrey Epstein, his Estate, and other related individua

sentatives of the EVCP). As courts have held, such statements are not subject to subpoena, even when sought from a third party. See United States v. Yudong Zhu, No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct. 14, 2014) (quashing request under Rule 17(h) for materials that "likely constitut

rnment explained in its opposition to that motion, the Government understands that Minor Victim-2 stopped writing in her diary shortly after meeting Jeffrey Epstein, so there are no entries regarding her later trip with Epstein, during which she met the defendant. (See Gov't Omnibus Response, Dkt. No. 204 at 18

tands that Minor Victim-2 stopped writing in her diary shortly after meeting Jeffrey Epstein, so there are no entries regarding her later trip with Epstein, during which she met the defendant. (See Gov't Omnibus Response, Dkt. No. 204 at 187). The victim provided the Government with her entries relatin

topped writing in her diary shortly after meeting Jeffrey Epstein, so there are no entries regarding her l

ness in this case; the Government will provide Carton with his 3500, Jencks and Giglio material by the deadline set by the Court"); United States v. Yudong Zhu, No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct. 14, 2014) (rejecting a subpoena request under Rule 17(h) even though the records

rnment explained in its opposition to that motion, the Government understands that Minor Victim-2 stopped writing in her diary shortly after meeting Jeffrey Epstein, so there are no entries regarding her later trip with Epstein, during which she met the defendant. (See Gov't Omnibus Response, Dkt. No. 204 at 18

tands that Minor Victim-2 stopped writing in her diary shortly after meeting Jeffrey Epstein, so there are no entries regarding her later trip with Epstein, during which she met the defendant. (See Gov't Omnibus Response, Dkt. No. 204 at 187). The victim provided the Government with her entries relatin

topped writing in her diary shortly after meeting Jeffrey Epstein, so there are no entries regarding her l

ness in this case; the Government will provide Carton with his 3500, Jencks and Giglio material by the deadline set by the Court"); United States v. Yudong Zhu, No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct. 14, 2014) (rejecting a subpoena request under Rule 17(h) even though the records