{
  "document_metadata": {
    "page_number": "6",
    "document_number": "734-1",
    "date": "07/15/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 734-1 Filed 07/15/22 Page 6 of 7\n\n14. As a matter of public policy, ensuring confidentiality in litigation-alternative victim compensation programs like the EVCP is an absolute imperative. To compromise confidentiality in any way in this case would threaten the integrity, credibility and viability of this program and all others like it - past, existing, and future. It has been my experience that victims, alleged tortfeasors, other interested parties, and courts have long recognized and respected the need to protect confidentiality in victim compensation programs as integral to program integrity. I personally know of no situation in which an independent administrator has been forced to disclose information and/or documentation that was submitted to, maintained by, exchanged with or distributed by a litigation-alternative compensation program for any purpose. To open the door in any way would disembowel the very core of this program and have devastating consequences for this and other victim compensation programs, particularly those involving claims of sexual abuse. Forcing disclosure of Program records, despite the fact that confidentiality is an express, agreed-upon, court-mandated term of the Program, would invite and embolden others who are pursuing civil legal claims or who are facing criminal prosecution or who are pursuing criminal prosecution of others or who otherwise want to get their hands on confidential information to file similar requests.\n\n15. I designed the EVCP with confidentiality as a centerpiece and cornerstone of the claims process. Safeguarding that confidentiality in full and without condition is essential to the integrity and success of this Program, and the viability of other similar compensation programs.\n\n16. Ms. Maxwell's motion seeking authorization for this subpoena makes inaccurate statements about the Protocol. Ms. Maxwell's motion expressed that \"the Protocol credits claimants who have had charges filed against Epstein or any employee of Epstein.\" That is not an accurate characterization of the Protocol. The Protocol includes a non-exclusive list of factors\n\n6\n\nDOJ-OGR-00011472",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 734-1 Filed 07/15/22 Page 6 of 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "14. As a matter of public policy, ensuring confidentiality in litigation-alternative victim compensation programs like the EVCP is an absolute imperative. To compromise confidentiality in any way in this case would threaten the integrity, credibility and viability of this program and all others like it - past, existing, and future. It has been my experience that victims, alleged tortfeasors, other interested parties, and courts have long recognized and respected the need to protect confidentiality in victim compensation programs as integral to program integrity. I personally know of no situation in which an independent administrator has been forced to disclose information and/or documentation that was submitted to, maintained by, exchanged with or distributed by a litigation-alternative compensation program for any purpose. To open the door in any way would disembowel the very core of this program and have devastating consequences for this and other victim compensation programs, particularly those involving claims of sexual abuse. Forcing disclosure of Program records, despite the fact that confidentiality is an express, agreed-upon, court-mandated term of the Program, would invite and embolden others who are pursuing civil legal claims or who are facing criminal prosecution or who are pursuing criminal prosecution of others or who otherwise want to get their hands on confidential information to file similar requests.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "15. I designed the EVCP with confidentiality as a centerpiece and cornerstone of the claims process. Safeguarding that confidentiality in full and without condition is essential to the integrity and success of this Program, and the viability of other similar compensation programs.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "16. Ms. Maxwell's motion seeking authorization for this subpoena makes inaccurate statements about the Protocol. Ms. Maxwell's motion expressed that \"the Protocol credits claimants who have had charges filed against Epstein or any employee of Epstein.\" That is not an accurate characterization of the Protocol. The Protocol includes a non-exclusive list of factors",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "6",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011472",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "07/15/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "734-1",
      "DOJ-OGR-00011472"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Epstein case, discussing the importance of confidentiality in victim compensation programs. The text is well-formatted and legible, with no visible redactions or damage."
}