Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page1of16
Smith Villazor LLP
250 West 55th Street, 30th Floor
New York, New York 10019
www.smithvillazor.com
Patrick J. Smith
[email protected]
T 212.582.4400
SMITH | VILLAZOR
November 19, 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, 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 quash defendant Maxwell’s
subpoena directed to Ms. Feldman for certain documents of the EVCP concerning 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 program and essential to its success. In program documents, press releases,
and on its website, the EVCP and Ms. Feldman repeatedly emphasized the program’s promise of
confidentiality. That promise allowed for participation by victims who otherwise would have
been reluctant to share their stories. It also encouraged victims to compromise claims that might
otherwise have taken up substantial judicial resources. Only a confidential program can
DOJ-OGR-00011451