Writes on behalf of Roberta Kaplan. Argues that because the three administrators were hired/paid by the Estate, they cannot be independent. Proposes adding a fourth administrator selected by plaintiffs and requiring unanimous decisions.
This document is an email chain from November and December 2019 between Jordy Feldman (Administrator of the Epstein Victims' Compensation Program) and attorneys Roberta Kaplan and Kate Doniger (representing victims). The core conflict involves the independence of the Compensation Program; Kaplan's team argues that because the administrators were hired by the Estate, they lack independence, and proposes adding a fourth, plaintiff-selected administrator. Feldman rejects this proposal, citing the reputation and experience of his team (including Ken Feinberg and Camille Biros) and asserting the program's neutrality.
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