Troutman Sanders LLP

Troutman Sanders LLP 875 Third Avenue New York. New York 10022 troutman.com Bennet J. Moskowitz December 3, 2019 E-MAIL Sigrid S. McCawley, Esq. Boies Schiller Flexner LLP 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 Re: Estate of Jeffrey E. Epstein Dear Ms. McCawley: troutmari sanders We write in response to your letter dated November 22, 2019, posing two inquiries concerning the proposed Epstein Victims' Compensation Program (the "Program") presented by the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate") on November 14, 2019 to the Superior Court of the United States Virgin Islands (the "USVI Court") for approval. Our response does not constitute the Co-Executors' position regarding discovery (e.g., whether discovery is appropriate at this time or the information you requested is discoverable in the actions pending in the Southern District of New York); rather, we respond in order to further the parties' discussions concerni