734-01.pdf

Type

pdf

Source set

house-oversight-doj

Pages

7

Text status

Searchable text available

OCR confidence

0.9412153256996043

Original source

Extracted text

Case 1:20-cr-00330-PAE Document 734-1 Filed 07/15/22 Page 1 Off&wypiT A UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK vee eee xX UNITED STATES OF AMERICA, No. 20 Cr. 330 (AJN) Vv. GHISLAINE MAXWELL, Defendant. ve xX 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 

Case 1:20-cr-00330-PAE Document 734-1 Filed 07/15/22 Page2of7 exposures. I worked for the 9/11 Fund for over ten years before leaving in November 2019 to serve as Co-Designer and Administrator of the EVCP. 4, Compensation programs like the EVCP and the 9/11 Fund are designed as alternative dispute resolution mechanisms through which alleged victims of traumatic events have an opportunity to voluntarily and confidentially resolve related civil tort claims through a non-adversarial administrative process outside of court. 3. Confidentiality is a critical, cornerstone feature in compensation programs like the …

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