VILLAZOR

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

Villozor LIP 250 West 55th Street, 30th Floor New York, NY 10019 www.smithvillozor.com

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Dear Judge Nathan:

We represent Jordana H. 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 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 and (ii) request a briefing schedule for 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 behalf.

We are available should the Court have any questions.

Respectfully submitted,

Is/ J.

Ei J. Villazor LLP

cc: AUSA Alison Moe, AUSA Maurene Comey, AUSA Andrew Rohrbach, AUSA Lam Pomerantz, Christian R. Everdell, Esq., Jeffrey S. Pagliuca, Esq., Laura A. Menninger, Esq., Mark Stewart =, Esq., Bobbi C. Sternheim, Esq. (by e-mail)