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Case 1:20-cr-00330-PAE Document 734-1 Filed 07/15/22 Page 1 off&wyipit A
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
»4
UNITED STATES OF AMERICA,
No. 20 Cr. 330 (AJN)
Vv.
GHISLAINE MAXWELL,
Defendant.
x
Declaration of Jordana H. Feldman in support of
Motion to Quash Rule 17(c) Subpoena
Jordana H. Feldman, pursuant to 28 U.S.C. § 1746, declares under penalty of perjury as
follows:
1. I am the independent, neutral third-party administrator of the Epstein Victims’
Compensation Program (“EVCP” or “Program’’), the litigation-alternative program established to
confidentially resolve claims of sexual abuse against Jeffrey Epstein, his Estate, and other related
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 declaration.
3. I am a professional in the field of independent claims administration. I previously
served as the Deputy Special Master of the September 11th Victim Compensation Fund (“9/11
Fund”), a litigation-alternative program administered by the U.S. Department of Justice to
compensate victims who became sick or died as a result of their September 1 1th-related
DOJ-OGR-00011467