Epstein Secrets

EXHIBIT A UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. X No. 20 Cr. 330 (MN) Declaration of in support of Motion to Quash Rule 17(c) Subpoena pursuant to 28 U.S.C. § 1746, decla

individuals and entities. 2. I respectfully submit this declaration in support of the motion to quash a subpoena directed to me by the defendant Ghislaine Maxwell for certain documents submitted to, communications with, and payments issued by the EVCP. I have personal knowledge of the facts set forth in this

and without condition is essential to the integrity and success of this Program, and the viability of other similar compensation programs. 16. Ms. Maxwell's motion seeking authorization for this subpoena makes inaccurate statements about the Protocol. Ms. Maxwell's motion expressed that "the Protocol c

ity of other similar compensation programs. 16. Ms. Maxwell's motion seeking authorization for this subpoena

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

f New York, include claims for battery and intentional infliction of emotional distress by plaintiffs who said they met Epstein and his companion, Ghislaine Maxwell, between 1995 and 2002. By Tom McParland November 12, 2019 at 03:21 PM Boies Schiller Flexner attorneys on Tuesday sued the estate of Jeffrey Epste

, Epstein gropedn in a movie theater and eventually flew the girl to his New Mexico ranch, where he assaulted her. In her own lawsuit, .= said that Maxwell, a British socialite who has been accused of procuring young women and underage girls for Epstein, pressured her to have physical contact with Epste

ffs who said they met Epstein and his companion, Ghislaine Maxwell, between 1995 and 2002. By Tom McParland

n the United States Virgin Islands, where the mysteriously wealthy Mr. Epstein had his will filed shortly before his death. The estate has retained Kenneth R. Feinberg, the noted lawyer who specializes in compensating victims, to set up the program, his team confirmed late Wednesday. His associates Camille Biros an

Information. or Objects in a Criminal Case UNITED STATES DISTRICT COURT for the Southern District of New York United States of America auslaine Maxwell Defendant To. Jordana Feldman Case No. 20CR330 (MN) SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS IN A CRIMINAL CASE (Name of person

L) CLERK OF COURT Signature of Clerk or Deputy Clerk The name, address, e-mail, and telephone number of the attorney representing (name of party) Ghislaine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca, Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203, 303.831.7364, j

ber of the attorney representing (name of party) Ghislaine Maxwell , who requests this subpoena, are: Jeff

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"

f New York, include claims for battery and intentional infliction of emotional distress by plaintiffs who said they met Epstein and his companion, Ghislaine Maxwell, between 1995 and 2002. By Tom McParland November 12, 2019 at 03:21 PM Boies Schiller Flexner attorneys on Tuesday sued the estate of Jeffrey Epste

roped in a movie theater and eventually flew the girl to his New Mexico ranch, where he assaulted her. In her own lawsuit EFTA00040557 said that Maxwell, a British socialite who has been accused of procuring young women and underage girls for Epstein, pressured her to have physical contact with Epste

ffs who said they met Epstein and his companion, Ghislaine Maxwell, between 1995 and 2002. By Tom McParland

n the United States Virgin Islands, where the mysteriously wealthy Mr. Epstein had his will filed shortly before his death. The estate has retained Kenneth R. Feinberg, the noted lawyer who specializes in compensating victims, to set up the program, his team confirmed late Wednesday. His associates Camille Biros an

f New York, include claims for battery and intentional infliction of emotional distress by plaintiffs who said they met Epstein and his companion, Ghislaine Maxwell, between 1995 and 2002. By Tom McParland November 12, 2019 at 03:21 PM Boies Schiller Flexner attorneys on Tuesday sued the estate of Jeffrey Epste

said, Epstein groped in a movie theater and eventually flew the girl to his New Mexico ranch, where he assaulted her. In her own lawsuit said that Maxwell, a British socialite who has been accused of procuring young women and underage girls for Epstein, pressured her to have physical contact with Epste

ffs who said they met Epstein and his companion, Ghislaine Maxwell, between 1995 and 2002. By Tom McParland

n the United States Virgin Islands, where the mysteriously wealthy Mr. Epstein had his will filed shortly before his death. The estate has retained Kenneth R. Feinberg, the noted lawyer who specializes in compensating victims, to set up the program, his team confirmed late Wednesday. His associates Camille Biros an

L) CLERK OF COURT Signature of Clerk or Deputy Clerk The name, address, e-mail, and telephone number of the attorney representing (name of party) Ghislaine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca. Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203, Notice to those

New York To: United States of America Ghislame Maxwell Defendant Case No. 20CR330 (MN) SUBPOENA TO PR

ber of the attorney representing (name of party) Ghislaine Maxwell , who requests this subpoena, are: Jeff

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

rable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New 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").

is "otherwise procurable" or, indeed, already in Ms. Maxwell's possession. See United States v. Pena, No. 15

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

m CLERK OF COURT Signature of Clerk or Depury, Clerk The name, address, e-mail, and telephone number of the attorney representing blame of party) Ghislaine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca. Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203, Notice to those

New York To: United States of America Ghislame Maxwell Defendant ) ) ) ) ) Case No. 20CR330 (MN) SUB

ber of the attorney representing blame of party) Ghislaine Maxwell , who requests this subpoena, are: Jeff

effrey Epstein ("Epstein"). The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims administration'. Kenneth R. Feinberg, Camille S. Biros and to design the Program. Ms. will also serve as the Administrator of the Program (the "Administrator"). This Protocol reflect

m CLERK OF COURT Signature of Clerk or Depury, Clerk The name, address, e-mail, and telephone number of the attorney representing blame of party) Ghislaine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca, Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203, Notice to those

t of New York United States of America Ghislame Maxwell Defendant To. Jordana Feldman ) ) ) ) ) Case

ber of the attorney representing blame of party) Ghislaine Maxwell , who requests this subpoena, are: Jeff

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"