Transcription of Handwriting in EFTA01681987-EFTA01681988

[3dithKohn]

{Page 1 - EFTA01681987}
11/6/19 - JE estate atty meeting
Executors:
- [illegible] compensation program - "fair + independent from them"
- above will face more claims this way b/c nonpublic
- must deal w/ USVI ct. why would spend more $ this way
- Indep. people to design + in program
- interviewed 7 candidates
- [illegible] views
- Admin + brokers will have complete autonomy + executors will have no authority to
reject or modify administrator's recommendation
- have to convince USVI court to allow (motion being put off)
- forging ahead as though don't need beneficiary buy-in + unclear if because
will get notice
- beneficiaries have not been notified of customs of trust
- USVI counsel advises that trustees of that don't have to give notice
as matter of law

- USAO agreed to maintain confidentiality of today's conversation re
identity of administrators pre filing of motion w/ identities
- hope to file next week, at latest 11/20/19

- Motion:
- request approval of ct to be able to enter into program
- engage administrators
- allow administrators to design + implement a plan
→ process of creating program will then be w/ input from [illegible] gov.
- not putting $ figure, but kind of asking for blank check

- administrators [illegible] some "free" stock
- expectation is they can start taking claims w/i 90 days
- would have website where can file claims + get info

- Eligibility = as inclusive as can be
- [illegible] exclusion
- risk [illegible] for litig will be taken into account by administrators
- unclear whether USA ct will be open to participation by Vs w/
prior settlements
→ discussed USAO's ability to provide compensation even to those
who previously settled through [illegible]
- adult victims [illegible] too

{Page 2 - EFTA01681988}
- Vs ca preserve claims + litigate if unhappy w/ claims admin, but
have if accept admin proposal
- have to stay litig. during program

Finding:
- open ended, no rap is idea from executors
- resistant to floor, but all proposes possible [illegible] forfeiture to
extent estate pays to Vs at least a certain amount

*Administrators (confidential)
1.) Jordy (Jordana) Feldman (9/11 victims fund) - interview victims [illegible]
2.) Ken Feinburg - designing program in 2 months

- Jordy will hire others to run program

- proposal for Gov't to meet w/ admins re program

https://www.justice.gov/epstein/files/D ... 681987.pdf