EFTA00030441.pdf

Independent
Epstein Victims' Compensation Program
PROTOCOL
DRAFT1
December 13, 2019

I. Purpose and Overview
The Epstein Victims' Compensation Program (the "Program") is a voluntary, independent Program that
has been established to compensate and resolve the claims of victims/survivors of sexual abuse by Jeffrey
Epstein ("Epstein").

The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims
administration experts Kenneth R. Feinberg, Camille S. Biros and Jordana H. Feldman to design the
Program. Ms. Feldman will also serve as the Administrator of the Program (the "Administrator").

Through the Program, the Estate wishes to acknowledge the wrongs endured by victims/survivors and
offer them an opportunity to voluntarily resolve their individual claims for such sexual abuse.

The Program is governed by the following non-exclusive guiding principles:
• The Program is purely voluntary. It does not affect any rights a victim may have
unless and until the Claimant accepts the offered compensation and executes a
Release. A Claimant may reject the offer of compensation and may stop participating
in the Program and withdraw the claim at any time prior to execution of the Release.
• The Program is independent and will in no way be administered, controlled or
overseen by the Estate. The Administrator is responsible for all decisions relating to
the review, processing and evaluation of individual claims submitted to the Program.
The Administrator will have final, binding and exclusive authority to determine
Claimant eligibility and the valuation of each eligible individual claim. Decisions of
the Administrator made pursuant to this Protocol are not subject to review or
modification in any way by the Estate or any other party or entity.
• There is no cap or limitation on the aggregate amount of funds available to
compensate all eligible Claimants or on the amount of compensation to be made to
each individual Claimant. Each individual claim will be evaluated separately by the
Administrator. The Administrator will determine, in her sole and exclusive discretion,
issues of eligibility and the amount of compensation.

1 This document is a draft of the Protocol governing the Program and is subject to input from victims/survivors, their lawyers,
other potentially interested parties, and representatives of the Estate.
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• All Claimants will be treated with respect, dignity and fairness without regard to race,
color, sexual orientation, national origin, religion, gender or disability. To ensure
claims will be adjudicated fairly, the Administrator will manage the process so that
all Claimants can equally access the Program's claim process. Individuals with
disabilities will be given the opportunity to effectively communicate their claims and
to request special process accommodations.

The Program will be effective within 90 days of approval by the Superior Court of the U.S. Virgin Islands
("Effective Date")2 and is available to all victims/survivors regardless of where they were harmed, when
they were harmed, whether the claim is time-barred by the applicable statute of limitations, and whether
they have previously filed a lawsuit against or settled with Epstein and/or the Estate.

The exclusive claims period for filing a claim pursuant to this Protocol shall commence on the to-be determined Effective Date and shall conclude nine (9) months after that date ("Filing Deadline"). All
individual claims filed with the Program must be postmarked within this period.

II. Eligibility Requirements
A. Eligibility Criteria
The persons eligible to participate in this Program are individuals who allege they were sexually abused
by Epstein. In addition, the following criteria apply:
• The claim of sexual abuse must be directed against Epstein.
• An individual whose claim is time-barred by the applicable statute of limitations may participate
in the Program provided that other eligibility criteria are met.
• An individual who previously entered into a settlement agreement resolving a claim of sexual
abuse against Epstein may participate in the Program provided that other eligibility criteria are
met.
• An individual who allegedly assisted Epstein in procuring other victims/survivors may participate
in the Program where there is a credible basis to determine that the individual acted under
duress as a result of her own sexual abuse by Epstein, provided that other eligibility criteria are
met.
• If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with
prejudice any existing lawsuits or legal actions or claims filed against the Estate or related entities
and/or individuals. The Claimant must provide proof of such dismissal along with or prior to the
signed acceptance letter and executed Release in order to receive payment.

2 The final version of the Protocol will include dates certain identifying the commencement date of the Program and
registration and filing deadlines, as explained below.
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B. Legal Representatives of Claimants
An individual may file a claim on a victim's behalf where that individual has been granted legal authority
to act in a representative capacity pursuant to appropriate law. The "Legal Representative" of an
individual Claimant shall mean: (1) in the case of a Claimant who is currently a minor, a parent or legal
guardian authorized by law to serve as the minor's legal representative; (2) in the case of an incompetent
or legally incapacitated Claimant, a person who has been duly appointed as the Claimant's legal
representative in accordance with applicable law; or (3) an attorney authorized to represent the Claimant
for purposes of pursuing a claim through this Program.

Legal Representatives must provide proper documentation demonstrating representative capacity. Such
proof may include a power of attorney, documentation showing the individual's appointment as guardian
or guardian ad litem, or a copy of a retainer agreement showing legal representation signed by both the
Claimant and the attorney.

III. Claims Administration - Submission, Evaluation and Determination
A. Claims Submission Process
Individuals who have filed a lawsuit, legal action or claim against Epstein and/or the Estate on or before
the Effective Date will be sent a Claim Form and other relevant Program information, including
Instructions for completion and submission of the Claim Form and a list of Frequently Asked Questions.

Individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the Estate on or
before the Effective Date may register to participate in this Program on the Program's website at
www.EpsteinVictimsCompensationProgram.com.3 To register, such individuals must complete a
questionnaire setting forth their name, contact information, a summary description of the nature of the
claim and other requested information. Upon registration, the Administrator will perform a preliminary
review to consider if the individual is eligible to participate in the Program. If the Administrator deems
that the individual is eligible to participate in the Program, she will then send that individual a Claim Form
and other relevant Program information.

Note: The fact that an individual is sent a Claim Form and other relevant Program information indicates
that the Administrator has determined that such individual is eligible to participate in the Program. It
does not indicate that the Administrator has determined that such individual is eligible to receive
compensation. That determination is made only after a Claim Form and all required documentation has
been submitted and evaluated by the Administrator.

Registrations will be accepted by the Administrator from the Effective Date through a date that is 45 days
prior to the Filing Deadline ("Registration Deadline"). It is important to note that the Registration Deadline
is separate from, and precedes, the Filing Deadline. As explained above, all claims must be filed by the
Filing Deadline.

3 This website is in the process of being developed and is yet operational.
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All Claim Forms must be completed and postmarked no later than the Filing Deadline. Claim Forms
should be mailed via overnight courier (a pre-paid courier voucher will be included with each packet) to
the Administrator at the following address or uploaded to the Program website at
www.EpsteinVictimsCompensationProgram.com:

Epstein Victims' Compensation Program
c/o Jordana H. Feldman, Administrator
[Address - To Be Inserted]

Claimants are invited to provide documentation identified in the Claim Form, and any other corroborating
or supporting information sufficient to substantiate the claim, satisfy eligibility requirements, and allow
the Administrator to review, process and evaluate the claim. If the claim is being presented by a Legal
Representative, then the Legal Representative will be responsible for submitting the necessary
documentation relating to the represented Claimant.

Additional documentation may be requested at the discretion of the Administrator. Both the Claimant
and the Estate will be afforded the opportunity to submit to the Administrator any information deemed
relevant to the Administrator's evaluation and determination of the claim before the Administrator's final
disposition of the claim.

If a Claimant submits an incomplete or deficient claim, the Administrator will notify the Claimant, explain
the additional information that is needed, and work with the Claimant or the Claimant's Legal
Representative (where applicable) to assist in submitting a complete claim.

B. Claims Evaluation and Determination
Claims will be evaluated in the order in which they are received, with the Administrator evaluating each
submitted individual claim in a prompt and fair manner. Claims will only be determined once all required
documentation has been submitted to the Administrator

1. Factors Considered in Evaluating Claims
As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
information available, whether the allegations of sexual abuse are credible. The Administrator will
consider appropriate factors and corroborative support, including but not limited to:
• The level of documentation, corroboration or other circumstantial evidence regarding the nature
and extent of the abuse, the frequency, location and other details of the abuse, and the age of
the victim at the time of the abuse. Non-exhaustive examples of such evidence include (i)
medical or psychiatric counseling/therapy records relevant to the abuse, and
(ii) contemporaneous written notification or other correspondence (e.g., letters, emails) of the
abuse by the Claimant to law enforcement authorities, parents, friends or others.
• Whether there exists any information and/or pertinent findings offered by the appropriate
Office of the District Attorney or other law enforcement agency.
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• Whether the Administrator finds the claims of the individual to be credible after complete review
of all relevant documentation and other evidence provided by the Claimant and the Estate.

As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
information available, the amount of compensation that should be offered to each eligible Claimant. The
Administrator will consider appropriate factors and corroborative support, including but not limited to:
• The nature, duration and extent of the sexual abuse suffered by the Claimant.
• The age of the Claimant at the time of the sexual abuse.
• The nature and extent of the Claimant's physical or psychological damage resulting from the
sexual abuse, and the effect of the sexual abuse on the Claimant.
• The credibility of the claim based upon all of the facts and circumstances, supporting
documentation and corroborating evidence.
• Whether the claim is time-barred under the applicable statute of limitations.
• Whether the Claimant previously entered into a settlement agreement with Epstein and received
a payment pursuant to such agreement.

The Administrator will confidentially send the Claimant a compensation determination letter including the
following: (1) the Administrator's eligibility decision regarding the claim; (2) the amount of compensation
offered; (3) a Release to be signed by the Claimant if the Claimant accepts the offered compensation; and
(4) a Payment Option Form. The Administrator's offer shall be valid for 60 days from the date of the
compensation determination letter.

The Administrator's determinations in this Program will not be binding on any potential criminal
investigation involving the same or similar allegations or Claimant.

2. Opportunities to be Heard
The Claimant will be afforded an opportunity to be heard, either before or after the Administrator renders
her determination. Upon request by the Claimant, the Administrator will be available to meet in person,
by video conference/Skype, or by teleconference to further discuss the claim. These meetings are
completely optional and voluntary. Requests to meet with the Administrator should be sent by email
claimantservices@epsteinvictimscompensationprogram.com4 and will be scheduled at a mutually
convenient time and location. The Administrator may also request a meeting with a Claimant or her Legal
Representative at a reasonable mutually convenient time and location, though the Claimant is not
obligated to attend any such meeting.

4 This email address is not yet active.
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3. Release
By submitting a claim to the Program, a Claimant is seeking to resolve all claims relating to allegations of
sexual abuse against Epstein and/or the Estate, related entities and/or individuals. If a Claimant chooses
to accept the offer of compensation pursuant to the Program, the Claimant will be required to sign and
execute a full Release, in a form satisfactory to the Estate, of all past and future claims relating to such
allegations of sexual abuse against the Estate, related entities and/or individuals. A Claimant may reject
the offer of compensation and may stop participating in the Program and withdraw the claim at any time
prior to the execution of the Release.

The Release will waive any rights the Claimant and her heirs, descendants, legatees or beneficiaries
may have to assert any claims relating to allegations of sexual abuse against the Estate, related entities
and/or individuals, to file an individual legal action relating to such allegations, or to participate in any
legal action associated with such allegations, except as a witness. However, the Release will not
operate to preclude or limit the Claimant's ability to report and discuss allegations of sexual abuse with
law enforcement officials or anyone else.

Before signing a Release, the Claimant must consult with an attorney. If the Claimant is not represented
by an attorney, the Program will provide an attorney to provide free legal counseling to the Claimant
for the sole purpose of advising the Claimant concerning the language and binding nature of the
Release.

No one affiliated with the Program will provide tax or legal advice to those receiving payments under
the Program. Claimants are urged to consult with a tax advisor concerning any questions regarding tax
liability for payments pursuant to the Program.

4. Payments
Upon the Claimant's acceptance of the Administrator's determination, the Administrator's receipt of
the Claimant's executed Release and, where applicable, dismissal with prejudice of any existing lawsuit
or legal actions or claims against the Estate or related entities and/or individuals, the Administrator will
initiate payment by check or electronic funds transfer to each eligible Claimant as directed by the
Claimant. Checks will be sent to Claimants via overnight courier service.

C. Program Integrity
For the purpose of protecting both the integrity of the Program and financial resources for eligible
Claimants, the Administrator will institute all necessary measures to prevent payment of fraudulent
claims, including taking steps to verify claims and analyze submissions for inconsistencies, irregularities
or duplication.
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Each Claimant who signs the Claim Form at the time of submission certifies that the information provided
in the Claim Form is true and accurate to the best of the Claimant's knowledge, and that the Claimant
understands that false statements or claims made in connection with such submission may result in fines,
imprisonment and/or any other remedy available by law. Claims that appear to be potentially fraudulent
or to contain false information will be forwarded to federal, state or local law enforcement agencies
and/or the appropriate Office of the District Attorney for possible investigation and prosecution.

D. Confidentiality/Privacy
The Program is confidential. By filing a claim with the Program, the Claimant or her Legal
Representative (where applicable) agrees that information submitted by the Claimant pursuant to the
Program will be used and/or disclosed by the Administrator and her designees only for the following
purposes:

1) Processing and evaluating the Claimant's claim;
2) Administering the Program and other Program-related work; and
3) Reports to law enforcement where appropriate.

When documents maintained or submitted by the Estate become part of a Claimant's file for purposes
of the Program, such materials will be reviewed by the Administrator to assist in processing and
evaluating the claim, but will otherwise remain confidential. These files are not available for inspection,
review or copying by the Claimant or her representatives during or after the Program, and all pertinent
settlement privileges and other privileges apply.

To protect the privacy of Claimants participating in the Program, all personal information provided by
the Claimant during this process will be returned or destroyed within one year after the conclusion of
the Program.

Individual Claimants are not bound by any rules of confidentiality. Claimants may, at their sole and
voluntary option, disclose information in their possession regarding their claim, their compensation and
their experience with the Program.

All confidentiality requirements are subject to law, regulation and judicial process.

The Administrator may, on a periodic basis, publish reports regarding the Program's claims processing or
other activities in an effort to provide transparency. Such reports will report on an aggregate level only.
No individual Claimant information will be published or disclosed in a way that compromises Claimant
confidentiality.
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