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Case 1:20-cr-00330-PAE Document 734-4 Filed 07/15/22 Page 1 of ° EXHIBIT D
Independent
Epstein Victims’ Compensation Program
PROTOCOL
May 29, 2020
I. PURPOSE AND OVERVIEW
The Epstein Victims’ Compensation Program (the “Program”) is a voluntary, independent Program that
has been established to compensate and resolve the claims of victims-survivors of sexual abuse by
Jeffrey Epstein (“Epstein”).
The Estate of Jeffrey Epstein (the “Estate”) has retained the services of nationally recognized claims
administration experts Kenneth R. Feinberg, Camille S. Biros and Jordana H. Feldman to design the
Program. Ms. Feldman will also serve as the Administrator of the Program (the “Administrator”). This
Protocol reflects input from victims-survivors, their lawyers, other potentially interested parties, and
representatives of the Estate.
Through the Program, the Estate wishes to acknowledge the wrongs endured by victims-survivors and
offer them an opportunity to voluntarily resolve their individual claims for such sexual abuse.
The Program is governed by the following non-exclusive guiding principles:
e The Program is purely voluntary. It does not affect any rights a Claimant may have
unless and until the Claimant accepts the offered compensation and executes a
Release. A Claimant may reject the offer of compensation and may stop
participating in the Program and withdraw the claim at any time prior to execution
of the Release.
e The Program is independent and will in no way be administered, controlled or
overseen by the Estate. The Administrator is responsible for all decisions relating to
the review, processing and evaluation of individual claims submitted to the
Program. The Administrator will have final, binding and exclusive authority to
determine Claimant eligibility and the valuation of each eligible individual claim.
Decisions of the Administrator made pursuant to this Protocol are not subject to
review or modification in any way by the Estate or any other party or entity.
e There is no cap or limitation on the aggregate amount of funds available to
compensate all eligible Claimants or on the amount of compensation to be made to
each individual Claimant. Each individual claim will be evaluated separately by the
Administrator. The Administrator will determine, in her sole and exclusive
discretion, issues of eligibility and the amount of compensation and the Estate will
pay all eligible claims based on the Administrator’s determination.
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