EFTA00027912.pdf

Type: pdf
Source set: data-set-8
Extracted text

From: Roberta Kaplan  
fr-" 
To:" 
)"  
Subject: Fwd: Epstein Victims' Compensation Program 
Date: Tue, 10 Dec 2019 16:48:48 +0000 
FYI 
Roberta ("Robbie") Kaplan, Esq. 
Kaplan Hecker & Fink LLP 
350 Fifth Avenue I Suite 7110 
New York, New York 10118 
From: Kate L Doniger 
Sent: Monday, December 9, 2019 4:55:53 PM 
To: Mariann Wang <->; 
Arick Fudali 
Daniel Mullkoff 
; Brad Edwards < 
>; Sigrid McCawley 4 
>; Sabina Mariella 
David Brodie 
Lisa Bloom < 
>; Brittany Henderson <
>; ECF <[email protected]>; Laura Starr 
Villacastin 
; Josh Schiller 
Benjamin Margulis < 
Andrew
; Andrew Buzin 
Cc: 
<a> 
Subject: FW: Epstein Victims' Compensation Program 
; Gloria Allred < 
Colleen Mullen 
; Julie Fink < 
; Alex Conlon 
All, 
FYI, please see below. Happy to discuss. 
Best, 
Kate 
Kate L. Doniger I Kaplan Hecker & Fink LLP 
35o Fifth Avenue I Suite 7110 
New York, New York ions 
(W) 
I(M) 
From: Kate L. Doniger 
Sent: Monday, December 9, 2019 4:47 PM 
To: lardy Feldman <
> 
Cc: 
cz
; Julie Fink 
Alex Conlon 
Rachel Harris <[email protected]>; 
Subject: RE: Epstein Victims' Compensation Program 
On behalf of Roberta Kaplan 
EFTA00027912


Jordy, 
Thank you for your email. We appreciate your commitment to a program that is independent of the Estate, which we also 
view as a central feature of any viable alternative to litigation. As I'm sure you can understand, however, a claims 
resolution program in which the three decision-makers were selected and hired by the Estate—and, we presume, are 
being paid by the Estate—cannot be said to be independent. In our view, there is a straightforward solution to this 
otherwise intractable problem: the program should add a fourth administrator, selected by plaintiffs, and require that all 
claims decisions are rendered unanimously. 
We look forward to discussing this proposal with you. We suggest arranging a time to do so before the protocol is 
finalized, since it will be important to incorporate the input of an additional administrator …
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