From: Roberta Kaplan <EIMINa>
To: 'S"
Cc: "Kate L. Doniger" -MINIE >, Alex Conlon
Subject: Fwd: Epstein Victims' Compensation Program
Date: Sat, 14 Dec 2019 14:55:17 +0000
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
350 Fifth Avenue I Suite 7110
New York New York 10118
From: Jordy Feldman < >
Sent: Saturday, December 14, 2019 9:46:10 AM
To: Kate L. Doniger c ).; Roberta Kaplan .: >; Julie Fink
< :.; Alex Conlon < >; Rachel Harris
Cc:
Subject: Re: Epstein Victims' Compensation Program
Roberta and Kate,
Ken, Camille and I have spent many years designing and running these types of claims resolution programs. Our
reputations rest on our credibility and independence, as demonstrated in those other programs, and we bring the same
independence and fair-mindedness to this Program. There is no need for an additional administrator. This Program will
be non-adversarial and will treat the victims with the dignity they deserve. We hope that you will meet with us and share
your feedback on the Draft Protocol. And, once the Program is up and running, we hope you will participate and see the
process for yourself.
Jordy
From: Kate L. Doniger ‹ >
Sent: Friday, December 13, 2019 5:17 PM
To: Jordy Feldman (t .>; Roberta Kaplan c ; Julie Fink
c ; Alex Conlon c ; Rachel Harris
Cc: ce;
<IN >
Subject: RE: Epstein Victims' Compensation Program
Jordy, Ken, and Camille
We have received the protocol and will get back to you. In the meantime, we would appreciate your response to our
proposal regarding the addition of an administrator selected by plaintiffs. Thank you,
Kate L. Doniger I Kaplan Hecker & Fink LLP
35o Fifth Avenue I Suite 7110
EFTA00019565
New York, New York low:
(W) (m) ■
From: Jordy Feldman <
Sent: Friday, December 13, 2019 2:00 PM
To: Roberta Kaplan ; Kate L Doniger Julie Fink
; Alex Conlon ; Rachel Harris < >
Cc:
Subject: Re: Epstein Victims' Compensation Program
Roberta,
I wanted to let you know that Ken, Camille and I have prepared a Draft Protocol for the Program, setting forth
the proposed criteria and requirements for the evaluation of claims, and the claims process. As you know, the
establishment of the Program is still pending approval by the Superior Court of the U.S. Virgin Islands. However,
we felt that it was important for us to move forward on the proposed design of the Program and to engage you
in the process as soon as possible.
To that end, we have attached a copy of the Draft Protocol, for your review and consideration. We welcome an
opportunity to meet with you to discuss any comments you may have. The comment period will run through
January 31, 2020.
Whenever you have a chance, please let us know if you are available to meet on any of the following dates:
December 18, January 6, 7, 8, 10, and 16. If none of those dates work, please provide alternate dates and
times, and we will try to coordinate schedules and set something up.
Looking forward to hearing your thoughts.
Regards,
Jordy, Ken and Camille
From: Kate L. Doniger
Sent: Monday, December 9, 2019 4:46 PM
To: Jordy Feldman <
Cc: Roberta Kaplan < ; Julie Fink < >; Alex Conlon
; Rachel Harris <= >;
Subject: RE: Epstein Victims' Compensation Program
On behalf of Roberta Kaplan
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.
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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.
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink L.I.P
350 Fifth Avenue I Suite 7110
New York. New York imi8
From: Jordy Feldman <
Sent: Wednesday, December 4, 2019 7:24 PM
To: Kate L. Doniger Roberta Kaplan
Cc: Julie Fink Alex Conlon >; Mariann Wang
>; Arick Fudali < >; Daniel Mullkoff > Brad
Edwards <->; Lisa Bloom < >; Brittany
Henderson <->; ECF <ecftWeplIc.com> Laura Starr < >•
Andrew Buzin Gloria Allred < ; Colleen
Mullen c );
Subject: RE: Epstein Victims' Compensation Program
Roberta,
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: Kate L. Doniger
Sent: Monday, December 2, 2019 9:05 PM
To: Jordy Feldman <
Cc: Roberta Kaplan ; Julie Fink < Alex Conlon
; Mariann Wang <->; Arick Fudali ; Daniel
Mullkoff •>; Brad Edwards < >; Lisa Bloom
; Brittany Henderson <->; ECF <ecf@eplIc.com>. Laura Starr
Andrew Buzin < ; Gloria Allred
; Colleen Mullen
Subject: RE: Epstein Victims' Compensation Program
On behalf of Roberta Kaplan
Jordy,
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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 I.I.P
350 Fifth Avenue I Suite 7110
New York, New York tott8
From: Jordy Feldman <
Sent: Monday, November 25, 2019 4:00 PM
To: Roberta Kaplan
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.
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,
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Jordy
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