Case 1:20-cr-00330-PAE Document479 Filed 11/21/21 Pagelof1
Smith Villazor LLP
250 West 55th Street, 30th Floor
SMITH | VILLAZOR New Yorks NY 10019
PATRICK J. SMITH
T 212 582 4400
[email protected]
November 15, 2021
BY E-MAIL to
[email protected]
The Honorable 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 Jordana H. Feldman, the independent administrator of the Epstein Victims’
Compensation Program, the litigation-alternative program established to confidentially resolve
claims of sexual abuse against Jeffrey Epstein, his Estate, and other related individuals and
entities. This afternoon we were informed by counsel for the government that the defendant has
sought, and the Court intends to authorize, a subpoena directed to Ms. Feldman under Federal
Rule of Criminal Procedure 17(c) for certain documents. We write to (1) inform the Court that
we are authorized to accept service of the subpoena on behalf of Ms. Feldman, and (ii) request a
briefing schedule for Ms. Feldman’s anticipated motion to quash the subpoena.
We understand that the government intends to file a motion to quash the subpoena, with a
deadline of this Wednesday, November 17, 2021. Given that we have just learned of the
subpoena today, the issues it presents, and mindful of the impending start date of trial, we
respectfully request until November 23, 2021 to file a motion to quash on Ms. Feldman’s behalf.
We are available should the Court have any questions.
Respectfully submitted,
/s/ Patrick J. Smith
Patrick J. Smith
Smith Villazor LLP
Ce: AUSA Alison Moe, AUSA Maurene Comey, AUSA Andrew Rohrbach, AUSA Lara
Pomerantz, Christian R. Everdell, Esq., Jeffrey S. Pagliuca, Esq., Laura A. Menninger,
Esq., Mark Stewart Cohen, Esq., Bobbi C. Sternheim, Esq. (by e-mail)
DOJ-OGR-00007357