SMITH > VILLAZOR ten Yor NY 009 USDC SDNY PATRICK J. SMITH DOCUMENT ELECTRONICALLY FILED T 212 582 4400 patrick.smithasmithvillazor.com DOC #; DATE FILED: The parties are ORDERED to docket any proposed redactions to this memo BY E-MAIL to ee endorsement and Administrator The Honorable Alison J. Nathan Feldman's letter by close of business United States District Judge on November 24, 2021. The Court Southern District of New York 40 Foley Square New York, New York 10007 November 23, 2021 will not extend the deadline for the parties’ proposed protective order, which must be submitted by 12:00 .m. today. SO ORDERED. Dear Judge Nathan: A\R () ike 11/24/21 Re: United States v. Maxwell, No. 20 Cr. 330 We represent Jordana H. Feldman, the independent administrator of the Epstein Victims’ Compensation Program. We write regarding the Court’s order, dated November 22, 2021, denying Ms. Feldman’s motion to quash Maxwell’s subpoena to her and ordering production of the subpoenaed documents by November 24, 2021 at noon. Ms. Feldman 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. SO ORDERED. We are available should the Court have any questions. Respectfully submitted, /s/ Patrick J. Smith Patrick J. Smith Smith Villazor LLP ce: AUSA AUSA i AUSA ES Aus, Christian R. Everdell, Esq., Jeffrey S. Pagliuca, Esq., Laura A. Menninger, Esq., Mark Stewart Cohen, Esq., Bobbi C. Sternheim, Esq. (by e-mail) EFTA00078746