SMITH VILLAZOR

SMITH VILLAZOR November 23, 2021 BY E-MAIL to The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FII.ED: 11 /24/2.1 Re: United States v. Maxwell, No. 20 Cr. 330 Dear Judge Nathan: Smith Viltozor LLP 250 West 55th Street. 30th Floor New York. NY 10019 www.smit hvIllo/ol.COT The parties are ORDERED to docket any proposed redactions to this memo endorsement and Administrator a letter by close of business on November 24, 2021. The Court will not extend the deadline for the parties' proposed protective order, which must be submitted by 12:00 p.m. today. SO ORDERED. Alti• 11/24/21 We represent the independent administrator of the Epstein Victims' Compensation Program. We write regarding the Court's order, dated November 22, 2021, denying 's motion to quash Maxwell's subpoena to her and ordering production of the subpoenaed documents by November 24, 2021 at noon. intends to comply with the Court's order and produce responsive documents to the Court. However, given the volume of materials and the steps necessary to ensure that documents produced fall within the scope of the subpoena, it is not possible to produce all materials by noon tomorrow. We understand that the volume of potentially responsive materials is approximately 6,000 to 7,000 pages, and we note that the original return date for the subpoena was November 29, 2021 at 8:30am. We intend to produce by noon tomorrow documents consisting of claim forms and any narratives signed by the four individuals identified in the subpoena, payment records, and releases executed by the four individuals. We intend to produce remaining responsive documents as soon as possible thereafter and respectfully request until November 29, 2021 at 8:30am (the original subpoena return date) to complete production. We are available should the Court have any questions. Respectfully submitted, • SO ORDERED. EFTA00078744