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Case 1:20-cr-00330-PAE Document 487 Filed 11/22/21 Page1of8
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
November 18, 2021
BY E-MAIL
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. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter motion to quash the defendant’s Rule
17(c)(3) subpoena to Jordana Feldman, the administrator of the Epstein Victims’ Compensation
Program (EVCP). For the reasons set forth below, the subpoena should be quashed. !
I. Applicable Law
As the defendant acknowledges, she bears the burden of satisfying the standard in United
States v. Nixon, 418 U.S. 683 (1974). (Def. Mot. at 1). Pursuant to that standard, the “party
seeking issuance of [a Rule 17(c)] subpoena must clear three hurdles: (1) relevancy; (2)
admissibility; (3) specificity.” United States v. Cole, 2021 WL 912425, at *3 (S.D.N.Y. Mar. 10,
2021) (internal quotation marks omitted). The proponent must also establish that the records
sought “are not otherwise procurable.” /d. (quoting Nixon, 418 U.S. at 699-700).
' For sake of simplicity, the Government uses the term “Minor Victims” to include Witness-3. The
Government acknowledges the Court’s order that Witness-3 should not be referenced at trial as a
victim.
DOJ-OGR-00007393