Document 479

Case 1:20-cr-00330-PAE Document 479 Filed 11/21/21 Page 1 of 1 Smith Villazor LLP 250 West 55th Street, 30th Floor New York, NY 10019 www.smithvillazor.com PATRICK J. SMITH T 212 582 4400 patrick.smith@smithvillazor.com November 15, 2021 BY E-MAIL to NathanNYSDChambers@nysd.uscourts.gov The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Maxwell, No. 20 Cr. 330 Dear Judge Nathan: We represent Jordana H. Feldman, the independent administrator of the Epstein Victims' Compensation Program, the litigation-alternative program established to confidentially resolve claims of sexual abuse against Jeffrey Epstein, his Estate, and other related individuals and entities. This afternoon we were informed by counsel for the government that the defendant has sought, and the Court intends to authorize, a subpoena directed to Ms. Feldman under Federal Rule of Criminal Procedure 17(c) for certain documents. We write to (i) inform the Court that we are authorized to accept service of the subpoena on behalf of Ms. Feldman, and (ii) request a briefing schedule for Ms. Feldman's anticipated motion to quash the subpoena. We understand that the government intends to file a motion to quash the subpoena, with a deadline of this Wednesday, November 17, 2021. Given that we have just learned of the subpoena today, the issues it presents, and mindful of the impending start date of trial, we respectfully request until November 23, 2021 to file a motion to quash on Ms. Feldman's behalf. We are available should the Court have any questions. Respectfully submitted, /s/ Patrick J. Smith Patrick J. Smith Smith Villazor LLP cc: AUSA Alison Moe, AUSA Maurene Comey, AUSA Andrew Rohrbach, AUSA Lara Pomerantz, Christian R. Everdell, Esq., Jeffrey S. Pagliuca, Esq., Laura A. Menninger, Esq., Mark Stewart Cohen, Esq., Bobbi C. Sternheim, Esq. (by e-mail) DOJ-OGR-00007357