{
  "document_metadata": {
    "page_number": "2",
    "document_number": "734",
    "date": "07/15/22",
    "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 2 of 16\n\nNovember 19, 2021\nPage Two\neffectively achieve the EVCP's important societal goals of providing redress to victims and efficiently resolving civil claims outside the glare of a public proceeding. Because Maxwell's subpoena would compromise that confidentiality and eviscerate the foundation of the EVCP and similar programs, compliance would be \"unreasonable or oppressive\" under Federal Rule of Criminal Procedure 17(c)(2). And because Maxwell's subpoena seeks information that is largely (if not entirely) inadmissible under Federal Rule of Evidence 408, it fails the test in United States v. Nixon, 418 U.S. 683, 702 (1974). Maxwell also seeks to subpoena statements of a witness or prospective witness that are not subject to subpoena under Federal Rule of Criminal Procedure 17(h). The subpoena should be quashed in its entirety.\n\nBackground\n\nThis background information comes principally from Ms. Feldman's declaration, which is submitted with this motion,1 and public documents about the EVCP, also attached as exhibits.\n\nA. Formation and Development of the EVCP\n\nIn November 2019, the co-executors of Epstein's estate (the \"Epstein Estate\") sought approval from a U.S. Virgin Islands court (where the Epstein Estate is being probated) to create a voluntary claims resolution program for victims of Epstein's sexual abuse.2 The program's design was led by Ms. Feldman, Kenneth R. Feinberg, and Camille S. Biros—all nationally recognized claims-administration experts.3 Mr. Feinberg is the nation's leading expert in crafting effective dispute resolution alternatives, and, with Ms. Biros, they have designed and\n\n1 Ex. A (Decl. of Jordana H. Feldman in Supp. of Mot. to Quash Rule 17(c) Subpoena (\"Feldman Decl.\")).\n2 Ex. B at 1 (Press Release, \"Administrator Jordana H. Feldman Announces Proposed Establishment of the Epstein Victims' Compensation Program,\" dated Nov. 14, 2019 (\"11/14/19 Press Release\"))\n3 Ex. C at 1 (Press Release, \"Renowned Claims Resolution Experts Announce Commencement of the Epstein Victims' Compensation Program,\" dated June 25, 2020 (\"6/25/20 Press Release\")); see Ex. A ¶ 3 (Feldman Decl.).\n\nDOJ-OGR-00011452",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page 2 of 16",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "November 19, 2021\nPage Two",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "effectively achieve the EVCP's important societal goals of providing redress to victims and efficiently resolving civil claims outside the glare of a public proceeding. Because Maxwell's subpoena would compromise that confidentiality and eviscerate the foundation of the EVCP and similar programs, compliance would be \"unreasonable or oppressive\" under Federal Rule of Criminal Procedure 17(c)(2). And because Maxwell's subpoena seeks information that is largely (if not entirely) inadmissible under Federal Rule of Evidence 408, it fails the test in United States v. Nixon, 418 U.S. 683, 702 (1974). Maxwell also seeks to subpoena statements of a witness or prospective witness that are not subject to subpoena under Federal Rule of Criminal Procedure 17(h). The subpoena should be quashed in its entirety.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Background",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "This background information comes principally from Ms. Feldman's declaration, which is submitted with this motion,1 and public documents about the EVCP, also attached as exhibits.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A. Formation and Development of the EVCP",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In November 2019, the co-executors of Epstein's estate (the \"Epstein Estate\") sought approval from a U.S. Virgin Islands court (where the Epstein Estate is being probated) to create a voluntary claims resolution program for victims of Epstein's sexual abuse.2 The program's design was led by Ms. Feldman, Kenneth R. Feinberg, and Camille S. Biros—all nationally recognized claims-administration experts.3 Mr. Feinberg is the nation's leading expert in crafting effective dispute resolution alternatives, and, with Ms. Biros, they have designed and",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 Ex. A (Decl. of Jordana H. Feldman in Supp. of Mot. to Quash Rule 17(c) Subpoena (\"Feldman Decl.\")).\n2 Ex. B at 1 (Press Release, \"Administrator Jordana H. Feldman Announces Proposed Establishment of the Epstein Victims' Compensation Program,\" dated Nov. 14, 2019 (\"11/14/19 Press Release\"))\n3 Ex. C at 1 (Press Release, \"Renowned Claims Resolution Experts Announce Commencement of the Epstein Victims' Compensation Program,\" dated June 25, 2020 (\"6/25/20 Press Release\")); see Ex. A ¶ 3 (Feldman Decl.).",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011452",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Ms. Feldman",
      "Kenneth R. Feinberg",
      "Camille S. Biros",
      "Epstein",
      "Jordana H. Feldman"
    ],
    "organizations": [
      "U.S. Virgin Islands court"
    ],
    "locations": [
      "U.S. Virgin Islands"
    ],
    "dates": [
      "November 19, 2021",
      "November 2019",
      "Nov. 14, 2019",
      "June 25, 2020",
      "07/15/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 734",
      "DOJ-OGR-00011452"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Epstein Victims' Compensation Program. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
}