{
  "document_metadata": {
    "page_number": "4",
    "document_number": "734",
    "date": "November 19, 2021",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page 4 of 16\n\nNovember 19, 2021\nPage Four\n\n2020, the U.S. Virgin Islands probate court approved the EVCP as designed.14 On June 25,\n2020, the EVCP announced that individuals could begin the process of filing claims.15\n\nIn her motion seeking approval for the subpoena, Maxwell makes at least two\nmischaracterizations of the Protocol for evaluating a claimant's eligibility for compensation.\n\nFirst, she says that the Protocol \"credits\" victims \"who have had charges filed against Epstein or\nany employee of Epstein.\"16 The Protocol does no such thing. It simply identifies the existence\nof any information or findings of law enforcement as one factor to be considered, as part of a\nnon-exhaustive list of \"appropriate factors and corroborative support\" that the administrator may\nconsider in evaluating claims.17 Maxwell also mischaracterizes the Protocol when she says that\nit \"rewards Accusers who have filed a lawsuit, legal action or claim of sexual abuse.\"18 This is\ninaccurate. As the Protocol makes clear, the existence of \"lawsuit[s], legal action[s] or claim[s]\"\nwas used to identify individuals as potential victims to send them claim forms.19 Individuals\nwho had not previously filed a lawsuit, legal action, or claim were also invited to register a claim\nwith the EVCP.20\n\nB. Key Features of the EVCP\n\nThe EVCP was designed with non-exclusive \"key features\" to provide \"an efficient and\nfair resolution of claims\" on a \"voluntary, non-adversarial, [and] confidential\" basis.21 For\nexample, the EVCP operates \"entirely free from any interference or control by the Epstein\n\n14 Ex. G (order of the Superior Court of the Virgin Islands Division of St. Thomas and St. John,\ndated June 2, 2020); see Ex. A ¶¶ 8, 13 (Feldman Decl.).\n15 Ex. C (6/25/20 Press Release).\n16 Maxwell's Mot. for an Order Authorizing a Subpoena Pursuant to Fed. R. Crim. P. 17(c)(3),\ndated Nov. 14, 2021 (\"Maxwell Mot.\"), at 3, 5.\n17 Ex. D at 5-6 (Protocol); see Ex. A ¶ 16 (Feldman Decl.).\n18 Maxwell Mot. at 3, 5.\n19 Ex. D at 4 (Protocol); see Ex. A ¶ 16 (Feldman Decl.).\n20 Ex. D at 4 (Protocol).\n21 See https://www.epsteinvcp.com/; see also Ex. D at 1-2 (Protocol).\n\nDOJ-OGR-00011454",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page 4 of 16",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "November 19, 2021\nPage Four",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "2020, the U.S. Virgin Islands probate court approved the EVCP as designed.14 On June 25,\n2020, the EVCP announced that individuals could begin the process of filing claims.15\n\nIn her motion seeking approval for the subpoena, Maxwell makes at least two\nmischaracterizations of the Protocol for evaluating a claimant's eligibility for compensation.\n\nFirst, she says that the Protocol \"credits\" victims \"who have had charges filed against Epstein or\nany employee of Epstein.\"16 The Protocol does no such thing. It simply identifies the existence\nof any information or findings of law enforcement as one factor to be considered, as part of a\nnon-exhaustive list of \"appropriate factors and corroborative support\" that the administrator may\nconsider in evaluating claims.17 Maxwell also mischaracterizes the Protocol when she says that\nit \"rewards Accusers who have filed a lawsuit, legal action or claim of sexual abuse.\"18 This is\ninaccurate. As the Protocol makes clear, the existence of \"lawsuit[s], legal action[s] or claim[s]\"\nwas used to identify individuals as potential victims to send them claim forms.19 Individuals\nwho had not previously filed a lawsuit, legal action, or claim were also invited to register a claim\nwith the EVCP.20",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "B. Key Features of the EVCP\n\nThe EVCP was designed with non-exclusive \"key features\" to provide \"an efficient and\nfair resolution of claims\" on a \"voluntary, non-adversarial, [and] confidential\" basis.21 For\nexample, the EVCP operates \"entirely free from any interference or control by the Epstein",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "14 Ex. G (order of the Superior Court of the Virgin Islands Division of St. Thomas and St. John,\ndated June 2, 2020); see Ex. A ¶¶ 8, 13 (Feldman Decl.).\n15 Ex. C (6/25/20 Press Release).\n16 Maxwell's Mot. for an Order Authorizing a Subpoena Pursuant to Fed. R. Crim. P. 17(c)(3),\ndated Nov. 14, 2021 (\"Maxwell Mot.\"), at 3, 5.\n17 Ex. D at 5-6 (Protocol); see Ex. A ¶ 16 (Feldman Decl.).\n18 Maxwell Mot. at 3, 5.\n19 Ex. D at 4 (Protocol); see Ex. A ¶ 16 (Feldman Decl.).\n20 Ex. D at 4 (Protocol).\n21 See https://www.epsteinvcp.com/; see also Ex. D at 1-2 (Protocol).",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011454",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Epstein"
    ],
    "organizations": [
      "U.S. Virgin Islands probate court",
      "Superior Court of the Virgin Islands"
    ],
    "locations": [
      "U.S. Virgin Islands",
      "St. Thomas",
      "St. John"
    ],
    "dates": [
      "November 19, 2021",
      "June 25, 2020",
      "June 2, 2020",
      "November 14, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "734",
      "DOJ-OGR-00011454"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Epstein Victim Compensation Program (EVCP). The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
}