Case 1:20-cr-00330-PAE Document504 _ Filed 11/24/21 Pagelof1
Smith Villazor LLP
250 West 55th Street, 30th Floor
SMITH | VILLAZOR —
PATRICK J. SMITH
T 212582 4400
[email protected]
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED:_11/24/21 The parties are ORDERED to docket
November 23, 2021 - :
any proposed redactions to this memo
BY E-MAIL to
[email protected] endorsement and Administrator
The Honorable Alison J. Nathan Feldman's letter by close of business
United States District Judge on November 24, 2021. The Court
i te District of New York will not extend the deadline for the
aero, York 10007 parties' proposed protective order,
which must be submitted by 12:00
Re: United States v. Maxwell, No. 20 Cr. 330 pee
Dear Judge Nathan: iV" \) ils
11/24/21
We represent Jordana H. Feldman, the independent administrator of the Epstem Victims’
Compensation Program. We write regarding the Court’s order, dated November 22, 2021,
denying Ms. Feldman’s motion to quash Maxwell’s subpoena to her and ordering production of
the subpoenaed documents by November 24, 2021 at noon.
Ms. Feldman intends to comply with the Court’s order and produce responsive
documents to the Court. However, given the volume of materials and the steps necessary to
ensure that documents produced fall within the scope of the subpoena, it is not possible to
produce all materials by noon tomorrow. We understand that the volume of potentially
responsive materials is approximately 6,000 to 7,000 pages, and we note that the original return
date for the subpoena was November 29, 2021 at 8:30am.
SO ORDERED.
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-00008037