From: Roberta Kaplan
To:

Subject: Fwd: Epstein Victims' Compensation Program

Date: Tue, 10 Dec 2019 16:48:48 +0000

FYI

Robert ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
350 Fifth Avenue | Suite 7110
New York, New York 10118

Subject: FW: Epstein Victims' Compensation Program

- From: Kate L. Doniger <redacted>
- Sent: Monday, December 9, 2019 4:55:53 PM
- To (visible recipients): Mariann Wang; Arick Fudali; Daniel Mullkoff; Brad Edwards; Sigrid McCawley; Sabina Mariella; Lisa Bloom; Brittany Henderson; ECF <ecf@epllc.com>; Laura Starr; Josh Schiller; Andrew Buzin; Benjamin Margulis; Andrew Villacastin; Gloria Allred; Colleen Mullen
- Cc (visible): Julie Fink; Alex Conlon; plus additional redacted recipients
- Note: Many email addresses/names in the To/Cc lines are blacked out.

Subject: FW: Epstein Victims' Compensation Program

All,

FYI, please see below. Happy to discuss.

Best,

Kate

Kate L. Doniger | Kaplan Hecker & Fink LLP
350 Fifth Avenue | Suite 7110
New York, New York 10118
(W) <empty> | (M) <empty>

From: Kate L. Doniger
Sent: Monday, December 9, 2019 4:47 PM
To: Jordy Feldman <<empty>>
Cc: <empty> <<empty>>; Julie Fink <<empty>>; Alex Conlon
<<empty>>; Rachel Harris <rharris@loeb.com>; <empty>

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 into that process. We will, of course, also raise this with the Estate.

("Robbie")

Hecker & Fink LLP

Esq.

350 Fifth Avenue | Suite 7110

New York, New York 10118

- Document type: Email header (screenshot)
- Sent: Wednesday, December 4, 2019, 7:24 PM
- From: [redacted]
- To: multiple recipients [redacted]
- Cc: multiple recipients [redacted]; includes visible email ecf@epllc.com
- Subject: RE: Epstein Victims' Compensation Program
- Visual notes: many recipient names and addresses are blacked out/redacted
- Associated context (provided): New York, New York 10118; body excerpt states the proposed Program is "entirely voluntary and independent of the Estate" and "will in no way be administered or controlled by the Estate."

Thank you for your email. I hear your concerns and want to reiterate that this proposed Program is entirely voluntary and independent of the Estate. It in no way imposes a process or outcome on the victims, and will in no way be administered or controlled by the Estate. Those are signature features of the Program.

As I mentioned in my email last week, Ken, Camille and I are in the process of drafting a claims protocol and plan to circulate it - in draft form — to you and your counterparts before the holidays, and welcome any input you may have at that time. We will provide ample time for you to review and respond to the draft protocol, and will be happy and available to discuss your comments before the protocol is finalized.

We look forward to speaking with you.

Regards, 
Jordy

From: [REDACTED]
Sent: Monday, December 2, 2019 9:05 PM
To: [REDACTED]
Cc: [REDACTED] (multiple recipients — at least 11 named contacts and a group/ECF address, all redacted in image)

EFTA00027913

- Type: Email header / recipient list (names and addresses), with heavy redactions (black bars).
- Subject (from surrounding text): "RE: Epstein Victims' Compensation Program"
- Layout: multiple recipients separated by semicolons; several names/address fields enclosed in angle brackets and partially or fully redacted.
- Visible details: several unredacted name strings are present among the redactions, but I can't identify or transcribe the real people’s names from the image.

Subject: RE: Epstein Victims' Compensation Program

## On behalf of

Jordy,

Thank you for reaching out to us. We are writing back on behalf of (and copying) certain plaintiffs' counsel who appeared at an SDNY conference last week for sexual abuse survivors of Epstein. We intend no disrespect to you and your colleagues, but, candidly, we have serious concerns about the Estate's purported decision to impose a non-binding settlement process on our clients unilaterally. All of these women still struggle today because of the profound manipulation, objectification, and physical abuse to which Jeffrey Epstein subjected each of them. Regardless of your own significant experience and good intentions, the fact that the Estate chose an administrator without any participation, input, or consideration of our clients' views or wishes is disconcerting, particularly given the personal nature of the claims at issue.

We are, of course, interested above all in advancing our clients' interests. As you may know, at a status conference last week in the Southern District, Magistrate Judge Freeman instructed counsel for the Estate and counsel for plaintiffs to engage in good faith discussions about any proposed claim resolution program. We have already directed a request for information on the proposed program to Bennet Moskowitz, and look forward to his response and to a productive dialogue with counsel ahead of the Jan. 10, 2019 deadline set by the Magistrate for an update on the status of our negotiations. Assuming that our settlement discussions with Defendants progress, we look forward to working with you at the appropriate time to design an effective and appropriate settlement program.

Roberta ("Robbie") Kaplan, Esq. Kaplan Hecker & Fink LLP 350 Fifth Avenue | Suite 7110 New York, New York 10118

From: Jordy Feldman
Sent: Monday, November 25, 2019 4:00 PM
To: 
Cc: 
Subject: Epstein Victims' Compensation Program

Roberta,

As you know, I will be serving as co-Designer, along with Ken Feinberg and Camille Biros, and Administrator of the proposed Epstein Victims' Compensation Program. I wanted to reach out to you to introduce myself, as I understand that you represent victims who have asserted, or may assert, claims of sexual abuse against Jeffrey Epstein or his Estate. I also wanted to reinforce the key guiding principles of the Program and give you a sense of timing in the near term.

This proposed Program is purely voluntary, non-adversarial and entirely independent of the Estate. The Estate will have no authority whatsoever to interfere with the administration of the Program or the evaluation of individual claims.

EFTA00027914

Ken, Camille and I are in the process of drafting a proposed protocol - setting forth the proposed terms, conditions, and criteria that will govern the Program - and plan to circulate a draft protocol before the end of the year. We will be seeking your input at that time in whatever format you would like to provide it, through a meeting with us and/or written comments, before the protocol is finalized.

We look forward to serving these deserving victims.

Regards,

Jordy

This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client work product or other applicable legalprivilege. If you are not the intended recipient of the email. please be aware that any unauthorized review. use. disclosure. dissemination. distribution, or copying of this communication. or any ofits contents. is strictly prohibited. If you have received this communication in error. please notify the sender immediately and destroy all copies of the message from your computer system. Thank you.

This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client. work product or other applicable legalprivilege. If you are not the intended recipient of the email. please be aware that any unauthorized review. use. disclosure. dissemination. distribution, or copying of this communication. or any ofits contents. is strictly prohibited. If you have received this communication in error, please notify the sender immediately and destroy all copies of the message from your computer system. Thank you.

EFTA00027915